On July 12, 2023 a
REPLY TO CROSS-CLAIM (S) - Reply to Vintage Firearms LLC
was filed
involving a dispute between
Brooklyn Hough,
Christopher Braden,
Garnell W. Whitfield Jr.
Individually And As Administrator Of The Estate Of Ruth E. Whitfield,
Jennifer Flannery
As Public Administrator Of The Estate Of Roberta Drury,
Jo-Ann Daniels,
Kimberly J. Salter
Individually And As Executrix Of The Estate Of Aaron W. Salter, Jr.,
Kisha Douglas,
Margus D. Morrison Jr.
Individually And As Administrator Of The Estate Of Margus Morrison, Sr.,
Mark L. Talley Jr.
Individually And As Administrator Of The Estate Of Geraldine C. Talley,
Pamela O. Prichett
Individually And As Executrix Of The Estate Of Pearl Lucille Young,
Robia Gary
Individually And As Parent And Natural Guardian Of A.S., A Minor,
Tirza Patterson
Individually And As Parent And Natural Guardian Of J.P., A Minor,
Zaire Goodman,
Zeneta Everhart
As Parent And Caregiver Of Zaire Goodman,
and
4Chan Community Support, Llc,
4Chan, Llc,
Alphabet, Inc,
Amazon.Com, Inc,
Blake Waldrop,
Cory Clark,
Discord, Inc,
Good Smile Company, Inc,
Good Smile Company U.S., Inc,
Good Smile Connect, Llc,
Google, Llc,
Instagram, Llc,
Jimay'S Flea Market, Inc.,
Jimays Llc,
Mean Arms, Llc
D B A Mean Arms,
Meta Platforms
F K A Facebook,
Pamela Gendron,
Paul Gendron,
Reddit, Llc,
Rma Armament, Inc
D B A Rma,
Snap, Inc,
Twitch Interactive, Inc.,
Vintage Firearms, Llc,
Youtube, Llc,
for Torts - Product Liability (Social Media Companys')
in the District Court of Erie County.
Preview
FILED: ERIE COUNTY CLERK 04/19/2024 12:14 PM INDEX NO. 808604/2023
NYSCEF DOC. NO. 343 RECEIVED NYSCEF: 04/19/2024
NEW YORK STATE SUPREME COURT
COUNTY OF ERIE
KIMBERLY J. SALTER, individually and as
Executrix of the ESTATE OF AARON W. SALTER,
JR.; MARGUS D. MORRISON, JR., individually and
DEFENDANT JIMAYS LLC’S
as Administrator of the ESTATE OF MARGUS
REPLY TO VINTAGE
MORRISON, SR.; PAMELA O. PRICHETT FIREARMS, LLC’S
individually and as Executrix of the ESTATE OF CROSSCLAIM
PEARL LUCILLE YOUNG; MARK L. TALLEY, JR.,
individually and as Administrator of the ESTATE OF
Index No. 808604/2023
GERALDINE C. TALLEY; GARNELL W.
WHITFIELD, JR., individually and as Administrator of
the ESTATE OF RUTH E. WHITFIELD; JENNIFER
FLANNERY, as Public Administrator of the ESTATE
OF ROBERTA DRURY; TIRZA PATTERSON,
individually and as parent and natural guardian of J.P.,
a minor; ZAIRE GOODMAN; ZENETA EVERHART,
as parent and caregiver of Zaire Goodman;
BROOKLYN HOUGH; JO-ANN DANIELS;
CHRISTOPHER BRADEN; ROBIA GARY,
individually and as parent and natural guardian of A.S.,
a minor; and KISHA DOUGLAS,
Plaintiffs,
vs.
META PLATFORMS, INC., f/k/a FACEBOOK, INC.;
INSTAGRAM LLC; REDDIT, INC; AMAZON.COM,
INC.; TWITCH INTERACTIVE, INC.; ALPHABET,
INC.; GOOGLE, LLC; YOUTUBE, LLC; DISCORD,
INC.; SNAP, INC.; 4CHAN, LLC; 4CHAN
COMMUNITY SUPPORT, LLC; GOOD SMILE
COMPANY, INC.; GOOD SMILE COMPANY U.S.,
INC.; GOOD SMILE CONNECT, LLC; RMA
ARMAMENT, INC. D/B/A RMA; BLAKE
WALDROP; CORY CLARK; VINTAGE
FIREARMS, LLC; JIMAY’S FLEA MARKET, INC.;
JIMAYS LLC; MEAN ARMS LLC D/B/A MEAN
ARMS; and PAUL GENDRON and PAMELA
GENDRON,
Defendants.
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MURA LAW GROUP, PLLC • 930 RAND BUILDING • 14 LAFAYETTE SQUARE • BUFFALO, NEW YORK 14203
(716) 855-2800 • FAX (716) 855-2816
1 of 3
FILED: ERIE COUNTY CLERK 04/19/2024 12:14 PM INDEX NO. 808604/2023
NYSCEF DOC. NO. 343 RECEIVED NYSCEF: 04/19/2024
Defendant, JIMAYS LLC, by and through its attorneys, MURA LAW GROUP,
PLLC, as and for its answer to the crossclaim of Co-Defendant VINTAGE FIREARMS, LLC states
as follows, upon information and belief:
1. Denies all allegations contained in each paragraph of “CROSS CLAIM” of
Co-Defendant Vintage Firearms, LLC’s Answer with Cross Claim, dated April 8, 2024.
WHEREFORE, JIMAYS LLC respectfully requests judgment as follows:
A. Dismissing the cross claim of Co-Defendant Vintage Firearms, LLC as to
JIMAYS LLC;
B. Awarding attorneys’ fees, costs and disbursements; and
C. For such other and further relief to JIMAYS LLC as this Court may deem just,
proper, and equitable.
DATED: Buffalo, New York
April 19, 2024
s/James H. Cosgriff, III, Esq.
James H. Cosgriff, III
MURA LAW GROUP, PLLC
Attorneys for JIMAYS LLC
930 Rand Building, 14 Lafayette Square
Buffalo, New York 14203
(716) 855-2800
james.cosgriff@muralaw.com
TO: LEHMANN MAJOR LIST, PLLC
Sean R. List, Esq. (Admitted Pro Hac Vice)
Counsel for Defendant Vintage Firearms, LLC
6 Garvins Falls Road
Concord, NH 03301
(603) 715-2516
sean@nhlawyer.com
www.gun-lawyer.com
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MURA LAW GROUP, PLLC • 930 RAND BUILDING • 14 LAFAYETTE SQUARE • BUFFALO, NEW YORK 14203
(716) 855-2800 • FAX (716) 855-2816
2 of 3
FILED: ERIE COUNTY CLERK 04/19/2024 12:14 PM INDEX NO. 808604/2023
NYSCEF DOC. NO. 343 RECEIVED NYSCEF: 04/19/2024
Darlene L. Donald, Esq.
Counsel for Defendant Vintage Firearms, LLC
510 N. Rogers Ave., Apt. 1
Endicott, NY 13760-2238
(315) 727-4607
darlenedonald@hotmail.com
cc: All Counsel of Record Via NYSCEF
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MURA LAW GROUP, PLLC • 930 RAND BUILDING • 14 LAFAYETTE SQUARE • BUFFALO, NEW YORK 14203
(716) 855-2800 • FAX (716) 855-2816
3 of 3
Preview
FILED: ERIE COUNTY CLERK 04/19/2024 12:14 PM INDEX NO. 808604/2023 NYSCEF DOC. NO. 343 RECEIVED NYSCEF: 04/19/2024 NEW YORK STATE SUPREME COURT COUNTY OF ERIE KIMBERLY J. SALTER, individually and as Executrix of the ESTATE OF AARON W. SALTER, JR.; MARGUS D. MORRISON, JR., individually and DEFENDANT JIMAYS LLC’S as Administrator of the ESTATE OF MARGUS REPLY TO VINTAGE MORRISON, SR.; PAMELA O. PRICHETT FIREARMS, LLC’S individually and as Executrix of the ESTATE OF CROSSCLAIM PEARL LUCILLE YOUNG; MARK L. TALLEY, JR., individually and as Administrator of the ESTATE OF Index No. 808604/2023 GERALDINE C. TALLEY; GARNELL W. WHITFIELD, JR., individually and as Administrator of the ESTATE OF RUTH E. WHITFIELD; JENNIFER FLANNERY, as Public Administrator of the ESTATE OF ROBERTA DRURY; TIRZA PATTERSON, individually and as parent and natural guardian of J.P., a minor; ZAIRE GOODMAN; ZENETA EVERHART, as parent and caregiver of Zaire Goodman; BROOKLYN HOUGH; JO-ANN DANIELS; CHRISTOPHER BRADEN; ROBIA GARY, individually and as parent and natural guardian of A.S., a minor; and KISHA DOUGLAS, Plaintiffs, vs. META PLATFORMS, INC., f/k/a FACEBOOK, INC.; INSTAGRAM LLC; REDDIT, INC; AMAZON.COM, INC.; TWITCH INTERACTIVE, INC.; ALPHABET, INC.; GOOGLE, LLC; YOUTUBE, LLC; DISCORD, INC.; SNAP, INC.; 4CHAN, LLC; 4CHAN COMMUNITY SUPPORT, LLC; GOOD SMILE COMPANY, INC.; GOOD SMILE COMPANY U.S., INC.; GOOD SMILE CONNECT, LLC; RMA ARMAMENT, INC. D/B/A RMA; BLAKE WALDROP; CORY CLARK; VINTAGE FIREARMS, LLC; JIMAY’S FLEA MARKET, INC.; JIMAYS LLC; MEAN ARMS LLC D/B/A MEAN ARMS; and PAUL GENDRON and PAMELA GENDRON, Defendants. -1- MURA LAW GROUP, PLLC • 930 RAND BUILDING • 14 LAFAYETTE SQUARE • BUFFALO, NEW YORK 14203 (716) 855-2800 • FAX (716) 855-2816 1 of 3 FILED: ERIE COUNTY CLERK 04/19/2024 12:14 PM INDEX NO. 808604/2023 NYSCEF DOC. NO. 343 RECEIVED NYSCEF: 04/19/2024 Defendant, JIMAYS LLC, by and through its attorneys, MURA LAW GROUP, PLLC, as and for its answer to the crossclaim of Co-Defendant VINTAGE FIREARMS, LLC states as follows, upon information and belief: 1. Denies all allegations contained in each paragraph of “CROSS CLAIM” of Co-Defendant Vintage Firearms, LLC’s Answer with Cross Claim, dated April 8, 2024. WHEREFORE, JIMAYS LLC respectfully requests judgment as follows: A. Dismissing the cross claim of Co-Defendant Vintage Firearms, LLC as to JIMAYS LLC; B. Awarding attorneys’ fees, costs and disbursements; and C. For such other and further relief to JIMAYS LLC as this Court may deem just, proper, and equitable. DATED: Buffalo, New York April 19, 2024 s/James H. Cosgriff, III, Esq. James H. Cosgriff, III MURA LAW GROUP, PLLC Attorneys for JIMAYS LLC 930 Rand Building, 14 Lafayette Square Buffalo, New York 14203 (716) 855-2800 james.cosgriff@muralaw.com TO: LEHMANN MAJOR LIST, PLLC Sean R. List, Esq. (Admitted Pro Hac Vice) Counsel for Defendant Vintage Firearms, LLC 6 Garvins Falls Road Concord, NH 03301 (603) 715-2516 sean@nhlawyer.com www.gun-lawyer.com -2- MURA LAW GROUP, PLLC • 930 RAND BUILDING • 14 LAFAYETTE SQUARE • BUFFALO, NEW YORK 14203 (716) 855-2800 • FAX (716) 855-2816 2 of 3 FILED: ERIE COUNTY CLERK 04/19/2024 12:14 PM INDEX NO. 808604/2023 NYSCEF DOC. NO. 343 RECEIVED NYSCEF: 04/19/2024 Darlene L. Donald, Esq. Counsel for Defendant Vintage Firearms, LLC 510 N. Rogers Ave., Apt. 1 Endicott, NY 13760-2238 (315) 727-4607 darlenedonald@hotmail.com cc: All Counsel of Record Via NYSCEF -3- MURA LAW GROUP, PLLC • 930 RAND BUILDING • 14 LAFAYETTE SQUARE • BUFFALO, NEW YORK 14203 (716) 855-2800 • FAX (716) 855-2816 3 of 3