Party Statement: New York State Office Of Victim Services v. Juan T Ramirez

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                                FILED: ALBANY COUNTY CLERK 03/25/2024 04:01 PM                                                   INDEX NO. 902880-24
NYSCEF DOC. NO. 3                                                                       RECEIVED NYSCEF: 03/25/2024




          SUPREME COURT OF THE STATE OF NEW YORK
          COUNTY OF ALBANY
           In the Matter of the Application of the NEW YORK
           STATE OFFICE OF VICTIM SERVICES, on
           behalf of KR, the crime victim, and all other victims
           of respondent’s crimes,

                                               Petitioner,                  AFFIRMATION
                                                                            IN ASUPPORT OF
                      Pursuant to Executive Law ⸹632-a for                  ORDER TO SHOW
                          Preliminary Injunctive Relief                     CAUSE

                                   -against-                                Index No.

           JUAN T. RAMIREZ JR. (NYSID No. 09695879R),

                                               Respondent.



                 Stacey Hamilton, an attorney admitted to practice in the State of New York, affirms the

         following under penalty of perjury pursuant to CPLR 2106.

                 1.        I am an Assistant Attorney General, of counsel in this matter to Letitia James,

         Attorney General of the State of New York, attorney for Petitioner, the New York State Office of

         Victim Services.

                 2.        The matters contained in this affirmation are true to my knowledge, except as to

         those matters alleged on information and belief, and as to those matters, I believe them to be true.

                 3.        I make this affirmation in Support of the Order to Show Cause seeking the

         imposition of a temporary restraining order, freezing the whole or any portion of the of the legacy

         or distributive share of the Matter of the Estate of Juan Ramirez, Deceased, (Suffolk County

          Surrogate’s Court, File # 2023-2660), that is or may become payable to Respondent, JUAN T.

         RAMIREZ JR. (NYSID No. 09695879R), during the pendency of this proceeding and the service

         of an order granting the preliminary injunctive relief requested herein.




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FILED: ALBANY COUNTY CLERK 03/25/2024 04:01 PM                                                  INDEX NO. 902880-24
NYSCEF DOC. NO. 3                                                                     RECEIVED NYSCEF: 03/25/2024




                  4.      Upon information and belief, the subject funds are currently in the possession of

          Ivette Osorio, Esq. and The Osorio Law Firm, PLLC, as attorneys for the Estate in the Matter of

          the Estate of Juan Ramirez, Deceased, (Suffolk County Surrogate’s Court, File # 2023-2660).

                  5.      I contacted Ivette Osorio, Esq., via email on March 25, 2024, regarding the Order

          to Show Cause but, to date, have not communicated with her otherwise.

                  WHEREFORE, Petitioner respectfully requests that the Court grant the relief requested in

          the attached order to show cause.

          Dated: Albany, New York
                 March 25, 2024
                                                       Stacey Hamilton
                                                       Stacey Hamilton
                                                       Assistant Attorney General, of Counsel




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