On June 30, 2015 a
Motion-Secondary
was filed
involving a dispute between
Partners In Safety Inc.,
and
Cardworks Acquiring Llc,
Merrick Bank Corporation,
for Commercial
in the District Court of Nassau County.
Preview
INDEX NO. 604244/2015
(FILED: NASSAU COUNTY CLERK 08717/2015 12:41 PM
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 08/17/2015
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
Sitti a eRe ae eS Ree ee ce SEER eee
PARTNERS IN SAFETY INC.,
Plaintiff, Index No.: 604244/2015
-against- AFFIDAVIT OF
MICHAEL H. GIBSON
CARDWORKS ACQUIRING LLC and
MERRICK BANK CORPORATION,
Defendants.
STATE OF NEW YORK )
) ss.:
COUNTY OF NEW YORK )
MICHAEL H. GIBSON, being duly sworn, deposes and says:
1 lam an attomey admitted to practice before the courts of the State of New York
and a partner in the law firm of Satterlee Stephens Burke & Burke LLP, attorneys for
Defendants CardWorks Acquiring LLC and Merrick Bank Corporation in this action.
2. I respectfully submit this affidavit in support of Defendants’ motion, pursuant to
CPLR § 3211(a)(1), for an Order: (i) dismissing the Complaint of Plaintiff Partners In Safety
Inc. in its entirety as a result of having been brought in an incorrect venue; (ii) awarding
Defendants recovery of their costs associated with this action, including but not limited to
reasonable attorneys’ fees; and (iii) awarding Defendants such further relief as the Court deems
just and proper.
3 Annexed hereto as Exhibit A is a true and correct copy of Plaintiff's Complaint in
this action.
2275898_1
ZZAe
a
Michael H. Gibson
Sworn to before me this
14% day of August, 2015
Notary Public
MARILYN JUDA
Notary Public, State of New York
lo. O1JU4759632
Qualified in Queens County
Commission Expires June 30, 20, 13
2275898_1
_ Le
Document Filed Date
August 17, 2015
Case Filing Date
June 30, 2015
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
INDEX NO. 604244/2015 (FILED: NASSAU COUNTY CLERK 08717/2015 12:41 PM NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 08/17/2015 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU Sitti a eRe ae eS Ree ee ce SEER eee PARTNERS IN SAFETY INC., Plaintiff, Index No.: 604244/2015 -against- AFFIDAVIT OF MICHAEL H. GIBSON CARDWORKS ACQUIRING LLC and MERRICK BANK CORPORATION, Defendants. STATE OF NEW YORK ) ) ss.: COUNTY OF NEW YORK ) MICHAEL H. GIBSON, being duly sworn, deposes and says: 1 lam an attomey admitted to practice before the courts of the State of New York and a partner in the law firm of Satterlee Stephens Burke & Burke LLP, attorneys for Defendants CardWorks Acquiring LLC and Merrick Bank Corporation in this action. 2. I respectfully submit this affidavit in support of Defendants’ motion, pursuant to CPLR § 3211(a)(1), for an Order: (i) dismissing the Complaint of Plaintiff Partners In Safety Inc. in its entirety as a result of having been brought in an incorrect venue; (ii) awarding Defendants recovery of their costs associated with this action, including but not limited to reasonable attorneys’ fees; and (iii) awarding Defendants such further relief as the Court deems just and proper. 3 Annexed hereto as Exhibit A is a true and correct copy of Plaintiff's Complaint in this action. 2275898_1 ZZAe a Michael H. Gibson Sworn to before me this 14% day of August, 2015 Notary Public MARILYN JUDA Notary Public, State of New York lo. O1JU4759632 Qualified in Queens County Commission Expires June 30, 20, 13 2275898_1 _ Le