On January 05, 2022 a
Exhibit,Appendix
was filed
involving a dispute between
R.D. Geronimo, Ltd,
Richard J. Digeronimo,
and
Archstone Group Nyc Llc,
Michael Miller,
Property Analytix, Llc,
Royce Ashton Rowles,
Ryan Lin,
for Commercial Division - Contract
in the District Court of Nassau County.
Preview
FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021
NYSCEF DOC. NO. 197 RECEIVED NYSCEF: 08/10/2023
Exhibit V
FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021
NYSCEF DOC. NO. 197 RECEIVED NYSCEF: 08/10/2023
AFFIDAVIT OF JON P. ERICKSON
STATE OF NEW JERSEY )
) ss.:
COUNTY OF PASSAIC )
Jon P. Erickson, under the penalties ofperjury, deposes and states as follows:
1. I have known Neil B. Rice since 1994.
2. I know Rice to be a dmg dealer who sells cocaine and Oxycontin in and around
Mount Kisco, New York. Rice has been selling drugs for many years.
3. About five to six years ago, I was present at a dinner at a restaurant in Armonk,
New York along with Rice, Aaron Einsidler, and Aaron's wife, Sara Einsidler. Rice arranged this
dimier to discuss opening a social club in the area and he hoped Aaron and Sara would be paying
members ofthis club. Rice bought the group dinner and wine.
4. At this dinner, I saw Rice give Aaron and Sara a package of cocaine.
5. Rice told me on several occasions after that that he was selling cocaine to Aaron
aad Sara. One ofthe times he told me that he was dealing cocaine to Aaron and Sara was in 2018
or 2019, when he was still planning to open the social club and hoping that Aaron and Sara, and
other "exclusive" people, would be members.
6. Rice told me that he continued to sell cocaine to Aaron and Sara after that.
7. Very soon after Aaron and Sara died in the summer of 2020 of a drug overdose,I
visited Rice at his mother's house in White Plains. At this time, Rice was extremely upset. He
had lost a lot ofweight and he told me that he was very scared that he would be arrested in
connection with Aaron and Sara's deaths.
FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021
NYSCEF DOC. NO. 197 RECEIVED NYSCEF: 08/10/2023
8. He told me at this meeting, "They're coming after me," and, "I don't want to do
the forty years."
9. At the beginning ofthis visit, Rice frisked me to search me for a wire and asked
me to give him my phone, because, he told me, he was feeling paranoid about the risk to him,
based on the death ofAaron and Sara.
10. After this visit, Rice told me that, because he was afraid ofbeing arrested, he got
rid ofhis stash ofdrugs and also got rid ofguns that he owned.
11. I have read the complaint Rice filed against Lee Einsidler in Westohester Supreme
Court, in which Rice makes allegadons that he was friends with Aaron and Sara Einsidler, and
that they harassed him.
12. Based on Rice's statements to me and what I observed, I do not believe that Rice
was friends with Aaron and Sara. Instead, he was only their dmg dealer.
13. Based on Rice's statements to me and what I observed, I also do not believe that
Aaron and Sara committed the sexual abuse and haiassment that Rice alleges in his lawsuit.
Based on my long-standing relationship with Rice and his practice oftelling me personal stories
about what was happening in his life, I believe that he would have told me had Aaron aad Sara
done any ofthe things that Rice alleges in his lawsuit. But he never told me any such things.
FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021
NYSCEF DOC. NO. 197 RECEIVED NYSCEF: 08/10/2023
14. I have never observed Rice to have any specific psychological or mental
disabilities.
Dated: Wayne, New Jersey
November2,2021
^A^e/i>—>
Jon P Erickson
Swom to before me this 2nd
day ofNovember, 2021
It
N.( Public
ASHOK K GHOSH
% Notajy PuUk; • State of.NwJasty
Cbmmissiim »2331_52P.
My Comm,
Document Filed Date
August 10, 2023
Case Filing Date
January 05, 2022
Category
Commercial Division - Contract
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Preview
FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021 NYSCEF DOC. NO. 197 RECEIVED NYSCEF: 08/10/2023 Exhibit V FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021 NYSCEF DOC. NO. 197 RECEIVED NYSCEF: 08/10/2023 AFFIDAVIT OF JON P. ERICKSON STATE OF NEW JERSEY ) ) ss.: COUNTY OF PASSAIC ) Jon P. Erickson, under the penalties ofperjury, deposes and states as follows: 1. I have known Neil B. Rice since 1994. 2. I know Rice to be a dmg dealer who sells cocaine and Oxycontin in and around Mount Kisco, New York. Rice has been selling drugs for many years. 3. About five to six years ago, I was present at a dinner at a restaurant in Armonk, New York along with Rice, Aaron Einsidler, and Aaron's wife, Sara Einsidler. Rice arranged this dimier to discuss opening a social club in the area and he hoped Aaron and Sara would be paying members ofthis club. Rice bought the group dinner and wine. 4. At this dinner, I saw Rice give Aaron and Sara a package of cocaine. 5. Rice told me on several occasions after that that he was selling cocaine to Aaron aad Sara. One ofthe times he told me that he was dealing cocaine to Aaron and Sara was in 2018 or 2019, when he was still planning to open the social club and hoping that Aaron and Sara, and other "exclusive" people, would be members. 6. Rice told me that he continued to sell cocaine to Aaron and Sara after that. 7. Very soon after Aaron and Sara died in the summer of 2020 of a drug overdose,I visited Rice at his mother's house in White Plains. At this time, Rice was extremely upset. He had lost a lot ofweight and he told me that he was very scared that he would be arrested in connection with Aaron and Sara's deaths. FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021 NYSCEF DOC. NO. 197 RECEIVED NYSCEF: 08/10/2023 8. He told me at this meeting, "They're coming after me," and, "I don't want to do the forty years." 9. At the beginning ofthis visit, Rice frisked me to search me for a wire and asked me to give him my phone, because, he told me, he was feeling paranoid about the risk to him, based on the death ofAaron and Sara. 10. After this visit, Rice told me that, because he was afraid ofbeing arrested, he got rid ofhis stash ofdrugs and also got rid ofguns that he owned. 11. I have read the complaint Rice filed against Lee Einsidler in Westohester Supreme Court, in which Rice makes allegadons that he was friends with Aaron and Sara Einsidler, and that they harassed him. 12. Based on Rice's statements to me and what I observed, I do not believe that Rice was friends with Aaron and Sara. Instead, he was only their dmg dealer. 13. Based on Rice's statements to me and what I observed, I also do not believe that Aaron and Sara committed the sexual abuse and haiassment that Rice alleges in his lawsuit. Based on my long-standing relationship with Rice and his practice oftelling me personal stories about what was happening in his life, I believe that he would have told me had Aaron aad Sara done any ofthe things that Rice alleges in his lawsuit. But he never told me any such things. FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021 NYSCEF DOC. NO. 197 RECEIVED NYSCEF: 08/10/2023 14. I have never observed Rice to have any specific psychological or mental disabilities. Dated: Wayne, New Jersey November2,2021 ^A^e/i>—> Jon P Erickson Swom to before me this 2nd day ofNovember, 2021 It N.( Public ASHOK K GHOSH % Notajy PuUk; • State of.NwJasty Cbmmissiim »2331_52P. My Comm,