On November 25, 2014 a
Order to Show Cause
was filed
involving a dispute between
May B. Mushkin Revocable Trust,
and
Doe Individuals I Through X,
Plane Realty, Llc A Nevada Limited Liability Company,
Roe Corporations I Through X,
Victor Scotto An Individual,
for Contract (Non-Commercial)
in the District Court of Nassau County.
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FILED: NASSAU COUNTY CLERK 11/18/2015 05:01 PM INDEX NO. 606333/2014
NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 11/18/2015
SUPREME COURT OF THE STATE OF NEW YORK
COTINTY OF NASSAU
MAY B. MUSHKIN REVOCABLE TRUST, Index No. 606333114E
Plaintiff, AFFIRMATION IN OPPOSITION
-against- TO DEFENDANT
VICTOR SCOTTO'S
VICTOR SCOTTO, an individual, ORDER TO SHOW CAUSE
PLANE REALTY, LLC, a Nevada limited liability
company; DOE individuats I through X;
ROE corporations I through X,
Defendants.
STATEOFNEWYORK )
COI-INTY OF WESTCHESTER ) ss.:
ERIC STREICH, an attomey duly admitted to practice law in the Courts of the
State of New York, hereby affirms the following to be true under the penalties of perjury:
l. I am the attomey for the Plaintiff in this action and am fully familiar with the facts
and circumstances hereinafter set forth.
2. This Affrrmation, the accompanying Affidavit of Marc C. Hafer, swom to on
November 13, 2015, with the exhibits and Certificate of Conformity dated November 16, 2015
annexed thereto, and the accompanying Memorandum of Law, are submitted in opposition to
Defendant Victor Scotto's Order to Show Cause to stay enforcement of the judgment entered
against him.
3. I submit this affirmation for the purpose ofintroducing copies ofdocuments that
should be considered in connection with Plaintiffs opposition.
4. Attached hereto as Exhibit "D" is a copy ofthe February 13,2015 Order ofthe
District Court of Clark County, Nevada by District Court Judge Joanna S. Kishner denying
Victor Scotto's motion for relief from judgment.
5. Attached hereto as Exhibit "E" is a copy of the Stipulation with Victor Scotto,
dated September 21,2015, extending his time to respond to Plaintifls Subpoena Duces Tecum
to October 9, 2015.
Dated: White Plains, New York
November 18, 2015
ERIC STREICH, P.C.
Attomeys For Plaintiff
235 Main Street - Suite 420
white Plains, NY 10601-2421
914-421-0000
TO: Vincent W. Crowe, Esq.
BLEAKLEY PLATT & SCHMIDT, LLP
Attomeys for Defendant Victor Scotto
One North Lexington Ave
White Plains, NY 10601
914-287 -6t47
2
Document Filed Date
November 18, 2015
Case Filing Date
November 25, 2014
Category
Contract (Non-Commercial)
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FILED: NASSAU COUNTY CLERK 11/18/2015 05:01 PM INDEX NO. 606333/2014 NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 11/18/2015 SUPREME COURT OF THE STATE OF NEW YORK COTINTY OF NASSAU MAY B. MUSHKIN REVOCABLE TRUST, Index No. 606333114E Plaintiff, AFFIRMATION IN OPPOSITION -against- TO DEFENDANT VICTOR SCOTTO'S VICTOR SCOTTO, an individual, ORDER TO SHOW CAUSE PLANE REALTY, LLC, a Nevada limited liability company; DOE individuats I through X; ROE corporations I through X, Defendants. STATEOFNEWYORK ) COI-INTY OF WESTCHESTER ) ss.: ERIC STREICH, an attomey duly admitted to practice law in the Courts of the State of New York, hereby affirms the following to be true under the penalties of perjury: l. I am the attomey for the Plaintiff in this action and am fully familiar with the facts and circumstances hereinafter set forth. 2. This Affrrmation, the accompanying Affidavit of Marc C. Hafer, swom to on November 13, 2015, with the exhibits and Certificate of Conformity dated November 16, 2015 annexed thereto, and the accompanying Memorandum of Law, are submitted in opposition to Defendant Victor Scotto's Order to Show Cause to stay enforcement of the judgment entered against him. 3. I submit this affirmation for the purpose ofintroducing copies ofdocuments that should be considered in connection with Plaintiffs opposition. 4. Attached hereto as Exhibit "D" is a copy ofthe February 13,2015 Order ofthe District Court of Clark County, Nevada by District Court Judge Joanna S. Kishner denying Victor Scotto's motion for relief from judgment. 5. Attached hereto as Exhibit "E" is a copy of the Stipulation with Victor Scotto, dated September 21,2015, extending his time to respond to Plaintifls Subpoena Duces Tecum to October 9, 2015. Dated: White Plains, New York November 18, 2015 ERIC STREICH, P.C. Attomeys For Plaintiff 235 Main Street - Suite 420 white Plains, NY 10601-2421 914-421-0000 TO: Vincent W. Crowe, Esq. BLEAKLEY PLATT & SCHMIDT, LLP Attomeys for Defendant Victor Scotto One North Lexington Ave White Plains, NY 10601 914-287 -6t47 2