Legal Document: Ryan Urban, Gigi Group, Llc v. Hudson Capital Group Ventures, Llc

On April 03, 2023 a MEMORANDUM OF LAW IN OPPOSITION was filed involving a dispute between Gigi Group, Llc, Ryan Urban, and Hudson Capital Group Ventures, Llc, for Commercial - Contract in the District Court of New York County.

Preview
FILED: NEW YORK COUNTY CLERK 09/08/2023 03:38 PM INDEX NO. 651660/2023
NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 09/08/2023

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X
Index No. 651660/2023
RYAN URBAN and GIGI GROUP, LLC,
(Hon. Lyle E. Frank)
Plaintiffs,

-against-

HUDSON CAPITAL GROUP VENTURES, LLC,

Defendant.

--------------------------------------X

PLAINTIFFS’ MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT’S PRE-
ANSWER MOTION TO DISMISS

ABRAMS FENSTERMAN, LLP
3 Dakota Drive, Suite 300
Lake Success, New York 11042
(516) 328-2300

Attorneys for Plaintiff

1 of 14
FILED: NEW YORK COUNTY CLERK 09/08/2023 03:38 PM INDEX NO. 651660/2023
NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 09/08/2023

TABLE OF CONTENTS

PRELIMINARY STATEMENT ........................................................................................................... 1
FACTS AS ALLEGED IN THE AMENDED COMPLAINT AND SUPPLEMENTED IN THE
ACCOMPANYING AFFIDAVIT IN OPPOSITION OF RYAN URBAN .......................................... 1
ARGUMENT ......................................................................................................................................... 3
I. THE AMENDED COMPLAINT SHOULD NOT BE DISMISSED ........................................ 3
A. The Amended Complaint States a Claim For Breach of Contract.......................................... 4
1. The Indemnification Language Does Not Insulate Hudson Capital From Liability. .......... 5
2. The Voluntary Payment Doctrine Does Not Bar Plaintiffs’ Claims. .................................. 7
3. The Documentary Evidence Does Not Conclusively Dispose of Plaintiffs’ Claims. ......... 8
B. The Amended Complaint States a Claim for Unjust Enrichment........................................... 8
CONCLUSION .................................................................................................................................... 10
ATTORNEY CERTIFICATION REGARDING WORD LIMIT ....................................................... 11

2 of 14
FILED: NEW YORK COUNTY CLERK 09/08/2023 03:38 PM INDEX NO. 651660/2023
NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 09/08/2023

TABLE OF AUTHORITIES

Cases
511 W 232nd Owner's Corp. v. Jennifer Realty Co., 98 N.Y.2d 144 (2nd Dept 2002) ............................ 3
Babylon Assocs. v. County of Suffolk, 101 A.D.2d 207 (2d Dep’t 1984)...................................................... 9
Cron v Hargro Fabrics, Inc., 91 N.Y.2d 362 (1998) .................................................................................... 3
Dodge v. King, 19 A.D.3d 359 (2nd Dept. 2005) ......................................................................................... 3
Dubrow v. Herman & Beinin, 157 A.D.3d 620 (1st Dept. 2018) .................................................................. 7
Ford v. Weishaus, 86 A.D.3d 421 (1st Dept. 2011) ....................................................................................... 8
Furia v. Furia, 116 A.D.2d 694 N.Y.S.2d 12 (2d Dep’t 1986) .................................................................... 4
Gross v Sweet, 49 N.Y.2d 102 (1979)........................................................................................................... 6
Jacob v. Macy's East, Inc., 262 A.D.2d 607 (2nd Dept 1999) ....................................................................... 4
JP Morgan Chase v. J.H. Elec. N.Y., Inc., 69 A.D.3d 802 N.Y.S.2d 237 (2d Dep’t 2010) .......................... 4
Kalisch-Jarcho, Inc. v City of New York, 58 N.Y.2d 377 (1983) ................................................................. 6
Kirby McInerney & Squire, LLP v Hall Charne Burce & Olson, S.C., 15 AD3d 233 (1st Dept 2005) ........ 8
Mazur Bros. Realty, LLC v. State of New York, 59 A.D.3d 401 (2nd Dept 2009) .................................. 3
Poole v. MCPJF, Inc., 127 A.D.3d 949 (2nd Dept. 2015); Ford v. Weishaus, 86 A.D.3d (1st Dept. 2011) . 8
Quesada v. Global Land, Inc., 35 A.D.3d 575, 576 (2nd Dept 2006)............................................................ 4
Reape v New York News, Inc., 122 AD2d 29 [2d Dept 1986] ...................................................................... 5
Rentways, Inc. v O'Neill Milk & Cream Co., 308 NY 342 [1955]................................................................ 6
Rite Aid of N.Y., Inc. v Chalfonte Realty Corp., 105 AD3d 470 (1st Dept 2013) .......................................... 8
Rovello v. Orofino Realty Co., 40 N.Y.2d 633 (1976) .................................................................................. 3
See also, Man Advisors, Inc. v Selkoe, 174 A.D.3d 435 (1st Dept 2019) ...................................................... 3
Selby v. Stewart, 19 Misc.3d 310 (Sup. Ct. Kings Cnty 2008) ................................................................... 3
Stay-Brite Servs., Inc. v. Sutton, 17 A.D.3d 570 (2nd Dept 2005) ................................................................. 4

Rules
CPLR 3014 ............................................................................................................................................... 2, 9
CPLR 3211 ............................................................................................................................................... 3, 4
CPLR 3211 (a)(2) ......................................................................................................................................... 4
CPLR 3211(a)(1) .......................................................................................................................................... 3
CPLR 3211(a)(7) ...................................................................................................................................... 3, 4
CPLR section 3017 ................................................................................................................................... 2, 9

3 of 14
FILED: NEW YORK COUNTY CLERK 09/08/2023 03:38 PM INDEX NO. 651660/2023
NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 09/08/2023

Plaintiffs, Ryan Urban (“Urban”) and GiGi Group, LLC (“GiGi”), by their attorneys,

Abrams Fensterman, LLP, respectfully submit this Memorandum of Law in opposition to
1
Defendant’s pre-Answer motion to dismiss the Amended Complaint in this action.

PRELIMINARY STATEMENT

Defendant, Hudson Capital Group Ventures, LLC (“Hudson Capital”) bases most, if not

all, of its motion on the argument that because Plaintiffs made several good faith payments to

Defendant, that somehow means that a breach of contract claim cannot be sustained. Hudson

Capital also asserts a self-serving interpretation of the indemnification clause in the parties’

contract/Engagement Letter which, if carried to the extent suggested by Hudson Capital, would

insulate them from any liability whatsoever. Clearly the parties did not intend to provide Hudson

Capital with a ‘get out of jail free card’ that would effectively grant them carte blanche to do (or

not do as the case may be) whatever they pleased without any resulting consequences.

In its moving papers, Hudson Capital selectively ignores the fact that all of the elements

of a breach of contract claim and an unjust enrichment claim have been properly pled in the

Amended Complaint, and that the unjust enrichment claim was specifically pleaded in the

alternative.

For these reasons, the pre-Answer motion to dismiss should be denied in its entirety.

FACTS AS ALLEGED IN THE AMENDED COMPLAINT AND SUPPLEMENTED IN
THE ACCOMPANYING AFFIDAVIT IN OPPOSITION OF RYAN URBAN

The Amended Complaint alleges two causes of action for breach of contract and unjust

1
Plaintiffs previously amended their Complaint in this action as of right, because the exhibit referenced therein had
been inadvertently omitted from the initial filing with the Court.

4 of 14
FILED: NEW YORK COUNTY CLERK 09/08/2023 03:38 PM INDEX NO. 651660/2023
NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 09/08/2023

enrichment. It sets forth that in or about July, 2021, the parties entered into a

contract/Engagement Letter, 2 and that pursuant to same, Hudson Capital was to provide advisory

and capital raising services in connection with the development and construction of a restaurant

and nightclub located at 138 Bowery, in Manhattan (the “Project”). It alleges that, while

Plaintiffs performed all obligations on their part (including making payments to Hudson Capital

aggregating $125,000), Hudson Capital breached the contract/Engagement Letter by failing to

provide advisory and capital raising services as required.

The Amended Complaint goes on to allege that any services provided by Hudson Capital

in connection with the Project were minimal and deficient; that the actions and/or inactions of

Hudson Capital constituted a breach of the parties’ contract/Engagement Letter; and that

Plaintiffs suffered resulting damages in an amount not less than the sum of $125,000.

The Amended Complaint also pleads, in the alternative, that if the parties’

contract/Engagement Letter is unenforceable or if for any reason Plaintiffs may not recover

thereunder, a cause of action for unjust enrichment by virtue of Hudson Capital’s receipt and

retention of payments aggregating the sum of $125,000, without having earned or otherwise

being entitled to same.

Hudson Capital does not argue that the Amended Complaint fails to state a viable cause

of action for unjust enrichment. Rather, they simply argue that it is duplicative of the breach of

contract cause of action, and for that reason only, should be dismissed. However, this argument

likewise fails, as pursuant to both CPLR 3014 and CPLR section 3017, Plaintiffs may properly

2
Plaintiffs concede that GiGi Group, LLC is not specifically listed as a party to the contract/Engagement Letter.
However, the contract/Engagement Letter is between Hudson Capital on the one hand, and Ryan Urban “and any
affiliated entities” on the other hand. As set forth in his accompanying Affidavit in Opposition, Urban is the sole
member of GiGi, which was being formed at the time the contract/Engagement Letter was being drafted. All
payments made to Hudson Capital came from GiGi. Accordingly, GiGi is also a proper party Plaintiff in this action.

5 of 14
FILED: NEW YORK COUNTY CLERK 09/08/2023 03:38 PM INDEX NO. 651660/2023
NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 09/08/2023

plead claims in the alternative. See also, Man Advisors, Inc. v Selkoe, 174 A.D.3d 435 (1st Dept

2019).

Having properly stated claims for breach of contract and unjust enrichment, at this pre-

Answer stage of the proceeding, Plaintiffs could simply rest upon their pleading. However,

Plaintiffs have also submitted herewith the Affidavit in Opposition of Plaintiff, Ryan Urban, 3

which discusses in depth the myriad of contractually agreed-upon tasks which Hudson Capital

failed to perform, and why the good faith payments were nevertheless made by Plaintiffs to

Hudson Capital.

Under the circumstances present here, the Amended Complaint should not be dismissed

by the Court.

ARGUMENT

I. THE AMENDED COMPLAINT SHOULD NOT BE DISMISSED

On a motion brought pursuant to CPLR 3211, the law is well settled that the Court

"...must accept as true the facts as alleged within the four corners of the complaint and accord

the plaintiffs the benefit of every possible favorable inference." Selby v. Stewart, 19 Misc.3d

310, 312 (Sup. Ct. Kings Cnty 2008); 511 W 232nd Owner's Corp. v. Jennifer Realty Co., 98

N.Y.2d 144 (2nd Dept 2002); Mazur Bros. Realty, LLC v. State of New York, 59 A.D.3d 401

(2nd Dept 2009); Dodge v. King, 19 A.D.3d 359 (2nd Dept. 2005).

When a party seeks dismissal on the grounds that its defense is founded upon

documentary evidence pursuant to CPLR 3211(a)(1), that party must submit documentary

evidence that resolves all factual issues as a matter of law. Mazur Bros. Realty, LLC v. State of

A plaintiff may supplement his allegations upon opposition to a motion to dismiss to remedy defects and buttress
3

otherwise meritorious claims See e.g. Cron v Hargro Fabrics, Inc., 91 N.Y.2d 362 (1998). See also, Rovello v.
Orofino Realty Co., 40 N.Y.2d 633, 635-36 (1976), explaining that, a plaintiff seeking to avoid dismissal under
CPLR 3211(a)(7) may “freely” use affidavits “to preserve inartfully pleaded, but potentially meritorious, claims.”

6 of 14
FILED: NEW YORK COUNTY CLERK 09/08/2023 03:38 PM INDEX NO. 651660/2023
NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 09/08/2023

New York, 59 A.D.3d 401 (2nd Dept 2009). The evidence must conclusively dispose of the claim.

See id.

Similarly, on a motion to dismiss a Complaint for a failure to state a cause of action

pursuant to CPLR 3211(a)(7), it is well established that:

"the pleading is to be liberally constru[ed] accepting all facts alleged in the
Complaint to be true ..." Jacob v. Macy's East, Inc., 262 A.D.2d 607, 608 (2nd
Dept 1999). Further, "[w]here evidentiary material is submitted on a CPLR
321l(a)(7) motion, it may be considered by the Court, but unless the defendant
demonstrates, without significant dispute, that a material fact alleged by the
complaint is not a fact at all, the motion will not be granted." Quesada v. Global
Land, Inc., 35 A.D.3d 575, 576 (2nd Dept 2006); see also Stay-Brite Servs., Inc. v.
Sutton, 17 A.D.3d 570 (2nd Dept 2005).

Applying the aforementioned standards, it is clear that the Amended Complaint states

viable claims for breach of contract and unjust enrichment, thereby compelling the denial of

Defendant’s pre-Answer motion to dismiss. 4

A. The Amended Complaint States a Claim For Breach of Contract

It is well settled that, in order to properly plead a claim for breach of contract, a plaintiff

must allege: (1) the existence of a contract or agreement between the parties; (2) performance by

plaintiff; (3) a failure to perform by the defendant; and (4) resulting damages. See e.g. JP

Morgan Chase v. J.H. Elec. of N.Y., Inc., 69 A.D.3d 802, 803, 893 N.Y.S.2d 237 (2d Dep’t

2010); Furia v. Furia, 116 A.D.2d 694, 498 N.Y.S.2d 12, 13 (2d Dep’t 1986).

In this case, Hudson Capital does not dispute the existence of the contract/Engagement

Letter between the parties. Likewise, Hudson Capital does not argue that Plaintiffs failed to

perform under that contract/Engagement Letter. To the contrary, Hudson Capital actually argues

4
Hudson Capital also moves pursuant to CPLR 3211 (a)(2) but does not appear to argue in its moving papers that
this Court lacks subject matter jurisdiction over this action. Accordingly, to the extent that any relief at all is sought
pursuant to CPLR 3211 (a)(2), the motion to dismiss should be denied.

7 of 14
FILED: NEW YORK COUNTY CLERK 09/08/2023 03:38 PM INDEX NO. 651660/2023
NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 09/08/2023

that because Plaintiffs performed under the parties’ contract/Engagement Letter and made

multiple good faith payments to Hudson Capital, that somehow excuses Hudson Capital’s failure

to perform as contracted. It does not.

As more fully discussed in the Affidavit in Opposition of Ryan Urban submitted

herewith, it was Hudson Capital that breached the parties’ contract/Engagement Letter by failing

to properly provide advisory services and by completely failing to perform capital raising

services as well. Zero capital was raised by Hudson Capital, even though paragraph “1” of the

parties’ contract/Engagement Letter spells out in detail Hudson Capital’s obligations in that

regard.

Accordingly, the Amended Complaint properly states a cause of action for breach of

contract.

1. The Indemnification Language Does Not Insulate Hudson Capital From Liability.

Rather than argue that they did perform under the contract/Engagement Letter, Hudson

Capital disingenuously claims that they are immune from liability based upon the “highly

idiosyncratic indemnification clause that absolved HCGV from liability arising from the services

they would provide Plaintiff” (see, Hudson Capital Memorandum of Law at pg. 12). Stated

differently, Hudson Capital has argued that, pursuant to contractual language which they

prepared, they could utterly fail to perform, and Plaintiffs would still have no recourse.

In the first instance, because the indemnification language at issue was undeniably

prepared by Hudson Capital, it must be construed against them. In that regard, it is a well settled

general rule of contract interpretation that ambiguities in an agreement must be interpreted most

strongly against the draftsman. See, Reape v New York News, Inc., 122 AD2d 29, 30 [2d Dept

1986].

8 of 14
FILED: NEW YORK COUNTY CLERK 09/08/2023 03:38 PM INDEX NO. 651660/2023
NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 09/08/2023

Further militating against Hudson Capital’s interpretation is the equally well-settled

maxim that, where there is ambiguity in the terms of a contract prepared by one of the parties, ‘it

is consistent with both reason and justice that any fair doubt as to the meaning of its own words

should be resolved against’ such party. See, Rentways, Inc. v O'Neill Milk & Cream Co., 308 NY

342, 348 [1955]

Practically speaking, if the Court were to approve Hudson Capital’s interpretation of the

indemnification language, it would effectively allow them to avoid the consequences of their

own breach of contract. Such a result would be unjust and inequitable.

In fact, such an interpretation is strongly disfavored. See e.g. Gross v Sweet, 49 N.Y.2d

102, 106 (1979) (holding that the law “frowns” upon indemnification clauses intended to

exculpate a party from the consequences of their own negligence or willful misconduct).

Indeed, it is well settled that exculpatory clauses (such as indemnification provisions)

will be deemed void or unenforceable “when, in contravention of acceptable notions of morality,

the misconduct for which it would grant immunity smacks of intentional wrongdoing. This can

be explicit, as when it is fraudulent, malicious or prompted by the sinister intention of one acting

in bad faith.” Kalisch-Jarcho, Inc. v City of New York, 58 N.Y.2d 377, 385 (1983).

In this case, Hudson Capital is seeking to hide behind an indemnification clause (which

they prepared), as they seek to escape liability for their own failure of performance. Even

assuming arguendo, the Court were to apply the indemnification language as sought by Hudson

Capital, it still would not absolve them of liability; as the language relied upon by Hudson

Capital specifically excludes acts by Hudson Capital that were in “bad faith”; that amounted to

“willful misconduct”; or were a result of their “failure or refusal to comply with… the services in

any manner or with HCGV’s obligations under this Agreement.”

9 of 14
FILED: NEW YORK COUNTY CLERK 09/08/2023 03:38 PM INDEX NO. 651660/2023
NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 09/08/2023

Accordingly, the indemnification language in the parties’ contract/Engagement Letter

does not bar Plaintiffs’ claims for either breach of contract or unjust enrichment.

2. The Voluntary Payment Doctrine Does Not Bar Plaintiffs’ Claims.

Somewhat perversely, Hudson Capital argues that because Plaintiffs performed their

obligations under the contract/Engagement Letter and made payments, in good faith, in

accordance with the “Compensation” requirements under section “3”, that somehow insulates

Hudson Capital from liability under the ‘voluntary payment doctrine.’ Undoubtedly, had

Plaintiffs not made those payments, Hudson Capital would be arguing that they could not

demonstrate the required “performance” element in order to sustain a breach of contract claim.

The ’voluntary payment doctrine’ does not apply here for several reasons. First, as

previously discussed, Plaintiffs were contractually obligated to make such payments. The fact

that they did so, in good faith, should not be used against them to shield Hudson Capital from

liability. Further, as more fully discussed in the accompanying Affidavit in Opposition of

Plaintiff, Ryan Urban, at the time payments were being made, Hudson Capital was repeatedly

promising to perform—particularly the capital raising services.

While Hudson Capital asserts that Plaintiffs “voluntarily” made payments to compensate

them for their services, they have not submitted any evidence to show that the amount of

Plaintiffs’ payments was fair and reasonably related to the value of services which they allegedly

rendered. They are required to do so. See, Dubrow v. Herman & Beinin, 157 A.D.3d 620 (1st

Dept. 2018).

Since Hudson Capital has not conclusively refuted Plaintiffs’ allegations, the ‘voluntary

payment doctrine’ does not apply here, and their motion to dismiss should properly be denied

10 of 14
FILED: NEW YORK COUNTY CLERK 09/08/2023 03:38 PM INDEX NO. 651660/2023
NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 09/08/2023

(See, Rite Aid of N.Y., Inc. v Chalfonte Realty Corp., 105 AD3d 470, 470-471 (1st Dept

2013); Kirby McInerney & Squire, LLP v Hall Charne Burce & Olson, S.C., 15 AD3d 233 (1st

Dept 2005)).

3. The Documentary Evidence Does Not Conclusively Dispose of Plaintiffs’ Claims.

Hudson Capital also argues that the documentary evidence which they have submitted

“conclusively” establishes that they performed as contracted for. It does nothing of the sort. In

fact, the “documentary evidence” submitted by Hudson Capital consists virtually exclusively of

e-mails discussing their various invoices and Plaintiffs’ payment of same.

Only one of the e-mails submitted by Hudson Capital even mentions the services

supposedly being performed. That e-mail stands alone and is not supported by any other

documentation to establish the performance of the advisory and/or capital raising services by

Hudson Capital. 5

Since these e-mails do not “conclusively dispose” of Plaintiffs’ claims, and since the

Court is required, within the context of Defendant’s pre-Answer motion to dismiss, to accept all

of the allegations in the Amended Complaint as true, it is respectfully submitted that the motion

to dismiss must be denied.

B. The Amended Complaint States a Claim for Unjust Enrichment

Plaintiffs’ claim for unjust enrichment is based upon the fact that it would be against

equity and good conscience to permit Hudson Capital to retain the payments made to it, without

having performed the services which they were obligated to perform. The Amended Complaint

5
Hudson Capital may not cure this fatal defect by submitting any such materials for the first time in its Reply
papers. See e.g., Poole v. MCPJF, Inc., 127 A.D.3d 949 (2nd Dept. 2015); Ford v. Weishaus, 86 A.D.3d 421, 422
(1st Dept. 2011) (holding that Supreme Court properly rejected movant’s “attempt to remedy a fundamental
deficiency in the moving papers by submitting evidentiary material with the reply”).

11 of 14
FILED: NEW YORK COUNTY CLERK 09/08/2023 03:38 PM INDEX NO. 651660/2023
NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 09/08/2023

specifically pleads this cause of action in the alternative (“[a]lternatively, if it be determined that

the parties’ contract/Engagement Letter is unenforceable or if for any reason that Plaintiffs may

not recover thereunder…).

Hudson Capital does not argue that the unjust enrichment claim is not properly pleaded.

Rather, they simply argue that it is supposedly duplicative of the breach of contract claim, and

therefore, should be dismissed. 6

Not only does this argument ignore the specific provisions of the CPLR which permit

pleading in the alternative (CPLR 3014 and CPLR section 3017), but it also ignores the case law

which expressly allows for pleading in the alternative—so long as the claim is expressly stated as

being in the alternative (as it does in this case). See, Babylon Assocs. v. County of Suffolk, 101

A.D.2d 207, 217 (2d Dep’t 1984).

For these reasons, it is respectfully submitted that Plaintiffs may properly maintain their

unjust enrichment claim (certainly at this initial pleading stage), and therefore, Defendant’s

motion to dismiss same should be denied.

6
Hudson Capital argues that its contract was with Ryan Urban. However, the payments made to it were undeniably
made by Urban’s company, GiGi. Thus, at the very least, the claims are not duplicative, as it can be argued that it is
Urban that holds the breach of contract claim, and GiGi that holds the unjust enrichment claim.

12 of 14
FILED: NEW YORK COUNTY CLERK 09/08/2023 03:38 PM INDEX NO. 651660/2023
NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 09/08/2023

CONCLUSION

For all of the foregoing reasons, it is respectfully submitted that Defendant’s pre-Answer

motion to dismiss the Amended Complaint should be denied, and that Plaintiffs should be

granted such other and further relief that the Court deems just, proper and equitable.

Dated: September 8, 2023

ABRAMS FENSTERMAN, LLP

By:_____________________________
Keith J. Singer
Alex Leibson
3 Dakota Drive, Suite 300
Lake Success, New York 11042
(516) 328-2300

Attorneys for Plaintiffs

13 of 14
FILED: NEW YORK COUNTY CLERK 09/08/2023 03:38 PM INDEX NO. 651660/2023
NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 09/08/2023

ATTORNEY CERTIFICATION REGARDING WORD LIMIT

I, Keith J. Singer, an attorney duly admitted to practice law before the courts of the State

of New York, hereby certify that the Memorandum of Law complies with the word count limit

set forth in Rule 202.8-b(a) because it contains 2,727 words, excluding the parts of the

Memorandum exempted by Rule 202.8-b (b). In preparing this certification, I have relied on the

word count of the word processing system used to prepare this Memorandum.

__________________________
Keith J. Singer, Esq.

14 of 14

Case Info

Judge

Lyle E. Frank Track Judge’s New Case

Case No.

(Subscribe to View)

Document Filed Date

September 08, 2023

Case Filing Date

April 03, 2023

County

Parties

For full print and download access, please subscribe at https://www.trellis.law/.

Document for Ryan Urban, Gigi Group, Llc v. Hudson Capital Group Ventures, Llc

Preview

Related Topics

Case Info

Parties