MEMORANDUM OF LAW IN SUPPORT - Memorandum in Support of Motion for Contempt

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                          (FILED: KINGS COUNTY CLERK 0773172017 12:58 PM INDEX NO. 512056/2015
NYSCEF DOC. NO. 62 RECEIVED NYSCEF: 07/31/2017

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS

MICHAEL VAHALA,
Plaintiff, |
-against- Index No. 512056/2015

SALMA VAHDAT, RALPH PFITZER, PAMELA
VAHDAT, THE ESTATE OF HASNA A. BESHEER

AND THE HASNA A. BESHEER REVOCABLE
TRUST,

Defendants.

MEMORANDUM IN SUPPORT OF MOTION FOR CONTEMPT
Petitioner submits this Memorandum in support of his motion to hold defendant
Salma Vahdat in civil contempt for failure to comply with the Court’s Order dated December 12,
2016 (Ex. A to the accompanying Affidavit of Richard J.J. Scarola sworn to July 31, 2017) (the
“Scarola Affidavit”), to pay a sanction, and for such other and further sanction and relief against

defendant Salma Vahdat as this Court deems just and proper.

Statement of Facts
The facts at issue are straightforward. Those facts are set forth in the Scarola
Affidavit. This Court sanctioned defendant Salma Vahdat i…