On February 16, 2024 a
Motion-Secondary
was filed
involving a dispute between
Joel Friedman,
and
Abraham Friedman,
for Other Matters - Contract - Other
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 04/22/2024 05:23 PM INDEX NO. 504754/2024
NYSCEF DOC. NO. 91 RECEIVED NYSCEF: 04/22/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS: PART 52
Index No. 504754/2024
JOEL FRIEDMAN
Assigned Justice:
Plaintiff, Hon. Francois Rivera
-against- Motion Sequence No. 4
ABRAHAM FRIEDMAN, AFFIRMATION OF
ABRAHAM FRIEDMAN
Defendant. IN SUPPORT OF
MOTION TO DISMISS
ABRAHAM FRIEDMAN hereby affirms under penalty of perjury pursuant to CPLR
2106:
1. I am the defendant in this action and, as such, have personal knowledge of the facts
set forth below.
2. I submit this affirmation in support of my motion to dismiss this action for lack of
personal jurisdiction over me, which is based on plaintiff Joel Friedman’s (“Joel”) failure to serve
me with process.
3. I have reviewed the so-called affidavit of service of this action upon me, a copy of
which is annexed as Exhibit 1.
4. I was surprised to see that Joel would resort to having me served with the unusual
method of taping legal papers to my door without even attempting to serve me with process at my
place of business.
5. My place of business is no secret. I am the principal of a company called ACM
Services Inc. (“ACM”), located at 185 Clymer Street, Brooklyn (Williamsburg), New York 11211.
A simple Google search (last accessed on April 21, 2024) shows that I am employed by ACM:
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FILED: KINGS COUNTY CLERK 04/22/2024 05:23 PM INDEX NO. 504754/2024
NYSCEF DOC. NO. 91 RECEIVED NYSCEF: 04/22/2024
6. As a known community supporter and activist (including as a chaplain for various
law enforcement agencies), it is no secret in our insular Orthodox Jewish community of
Williamsburg, Brooklyn that my place of business is at 185 Clymer.
7. Joel is my brother (if only he would act like it!)—and he knows full-well where my
place of business is.
8. Joel has personally been outside my office many times—both during better times
and also, unfortunately, when he was in his vendetta-fueled campaign against me.
9. In the 18 months or so since his latest jealousy flare-up, Joel has personally and
through proxies appeared outside my place of business many times to stalk me, intimidate me, and
harass me. (Joel’s menacing conduct has gotten so bad that I had to obtain an order of protection
against him. A copy is attached as Exhibit 2).
10. Joel also could have asked our mother (who he is tormenting with his vendetta and
baseless war against me) for the location of my place of business.
11. Joel also could have asked any one of our dozens of relatives for the location of my
place of business.
12. Joel also could have asked any one of our literally hundreds of common
acquaintances in our insular Orthodox Jewish community in Williamsburg for the location of my
place of business.
13. But Joel did not of that.
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FILED: KINGS COUNTY CLERK 04/22/2024 05:23 PM INDEX NO. 504754/2024
NYSCEF DOC. NO. 91 RECEIVED NYSCEF: 04/22/2024
14. The only supposed service I received of this lawsuit was a copy taped to the front
door of my home and then a copy in the mail.
15. It appears that Joel and his legal team were more interested in sending a subpoena
to Joel’s own counsel, Gary Snitow, Esq., to obtain a copy of our highly confidential and sensitive
settlement agreement—even though that agreement, by its own terms, can only be released at the
instruction of our chosen arbitrator, Rabbi Moshe Yonah Mandel, and only after an arbitration that
Joel himself agreed to.
16. Accordingly, I respectfully submit that this Court dismiss this action and grant me
such other and further relief as to this Court deems just and proper.
I affirm this 22nd day of April 2024, under the penalties of perjury under the laws of New York,
which may include a fine or imprisonment, that the foregoing is true, and I understand that this
document may be filed in an action or proceeding in a court of law.
______________________________
Abraham Friedman
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FILED: KINGS COUNTY CLERK 04/22/2024 05:23 PM INDEX NO. 504754/2024
NYSCEF DOC. NO. 91 RECEIVED NYSCEF: 04/22/2024
WORD COUNT CERTIFICATION
I, Ethan A. Kobre, an attorney admitted to practice before the Courts of the State of New
York, hereby certify that this Affirmation complies with the word count limits contained in Rule
202.8-b of the Uniform Rules of the Supreme Court of the State of New York because it contains
535 words, excluding the parts of the Affirmation excluded by that rule. In making this certification
I have relied upon the word count of the word-processing system used to prepare the memorandum,
i.e., Microsoft Word.
Dated: New York, New York
April 22, 2024
Ethan A. Kobre
Ethan A. Kobre
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Document Filed Date
April 22, 2024
Case Filing Date
February 16, 2024
Category
Other Matters - Contract - Other
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FILED: KINGS COUNTY CLERK 04/22/2024 05:23 PM INDEX NO. 504754/2024 NYSCEF DOC. NO. 91 RECEIVED NYSCEF: 04/22/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS: PART 52 Index No. 504754/2024 JOEL FRIEDMAN Assigned Justice: Plaintiff, Hon. Francois Rivera -against- Motion Sequence No. 4 ABRAHAM FRIEDMAN, AFFIRMATION OF ABRAHAM FRIEDMAN Defendant. IN SUPPORT OF MOTION TO DISMISS ABRAHAM FRIEDMAN hereby affirms under penalty of perjury pursuant to CPLR 2106: 1. I am the defendant in this action and, as such, have personal knowledge of the facts set forth below. 2. I submit this affirmation in support of my motion to dismiss this action for lack of personal jurisdiction over me, which is based on plaintiff Joel Friedman’s (“Joel”) failure to serve me with process. 3. I have reviewed the so-called affidavit of service of this action upon me, a copy of which is annexed as Exhibit 1. 4. I was surprised to see that Joel would resort to having me served with the unusual method of taping legal papers to my door without even attempting to serve me with process at my place of business. 5. My place of business is no secret. I am the principal of a company called ACM Services Inc. (“ACM”), located at 185 Clymer Street, Brooklyn (Williamsburg), New York 11211. A simple Google search (last accessed on April 21, 2024) shows that I am employed by ACM: 1 of 4 FILED: KINGS COUNTY CLERK 04/22/2024 05:23 PM INDEX NO. 504754/2024 NYSCEF DOC. NO. 91 RECEIVED NYSCEF: 04/22/2024 6. As a known community supporter and activist (including as a chaplain for various law enforcement agencies), it is no secret in our insular Orthodox Jewish community of Williamsburg, Brooklyn that my place of business is at 185 Clymer. 7. Joel is my brother (if only he would act like it!)—and he knows full-well where my place of business is. 8. Joel has personally been outside my office many times—both during better times and also, unfortunately, when he was in his vendetta-fueled campaign against me. 9. In the 18 months or so since his latest jealousy flare-up, Joel has personally and through proxies appeared outside my place of business many times to stalk me, intimidate me, and harass me. (Joel’s menacing conduct has gotten so bad that I had to obtain an order of protection against him. A copy is attached as Exhibit 2). 10. Joel also could have asked our mother (who he is tormenting with his vendetta and baseless war against me) for the location of my place of business. 11. Joel also could have asked any one of our dozens of relatives for the location of my place of business. 12. Joel also could have asked any one of our literally hundreds of common acquaintances in our insular Orthodox Jewish community in Williamsburg for the location of my place of business. 13. But Joel did not of that. 2 2 of 4 FILED: KINGS COUNTY CLERK 04/22/2024 05:23 PM INDEX NO. 504754/2024 NYSCEF DOC. NO. 91 RECEIVED NYSCEF: 04/22/2024 14. The only supposed service I received of this lawsuit was a copy taped to the front door of my home and then a copy in the mail. 15. It appears that Joel and his legal team were more interested in sending a subpoena to Joel’s own counsel, Gary Snitow, Esq., to obtain a copy of our highly confidential and sensitive settlement agreement—even though that agreement, by its own terms, can only be released at the instruction of our chosen arbitrator, Rabbi Moshe Yonah Mandel, and only after an arbitration that Joel himself agreed to. 16. Accordingly, I respectfully submit that this Court dismiss this action and grant me such other and further relief as to this Court deems just and proper. I affirm this 22nd day of April 2024, under the penalties of perjury under the laws of New York, which may include a fine or imprisonment, that the foregoing is true, and I understand that this document may be filed in an action or proceeding in a court of law. ______________________________ Abraham Friedman 3 3 of 4 FILED: KINGS COUNTY CLERK 04/22/2024 05:23 PM INDEX NO. 504754/2024 NYSCEF DOC. NO. 91 RECEIVED NYSCEF: 04/22/2024 WORD COUNT CERTIFICATION I, Ethan A. Kobre, an attorney admitted to practice before the Courts of the State of New York, hereby certify that this Affirmation complies with the word count limits contained in Rule 202.8-b of the Uniform Rules of the Supreme Court of the State of New York because it contains 535 words, excluding the parts of the Affirmation excluded by that rule. In making this certification I have relied upon the word count of the word-processing system used to prepare the memorandum, i.e., Microsoft Word. Dated: New York, New York April 22, 2024 Ethan A. Kobre Ethan A. Kobre 4 4 of 4