On December 19, 2019 a
Motion-Secondary
was filed
involving a dispute between
Kaja Sokola,
and
Disney Enterprises, Inc.,
Doe Corp. 1-10,
Harvey Weinstein,
Miramax Film Ny Llc F K A Miramax Film Corp.,
Miramax Film Ny Llc
F K A Miramax Film Corp.,
Robert Weinstein,
The Walt Disney Company,
for Torts - Child Victims Act
in the District Court of New York County.
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FILED: NEW YORK COUNTY CLERK 08/12/2020 10:59 PM INDEX NO. 950250/2019
NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 08/12/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
KAJA SOKOLA., Index No.: 950250/2019
Plaintiff, AFFIRMATION OF
IMRAN H. ANSARI IN
- against - SUPPORT OF MOTION
HARVEY WEINSTEIN, ROBERT WEINSTEIN, THE WALT
DISNEY COMPANY, DISNEY ENTERPRISES, INC.,
MIRAMAX HOLDING CORP., MIRAMAX FILM NY LLC
f/k/a MIRAMAX FILM CORP., and DOE CORP. 1-10,
Defendants.
IMRAN H. ANSARI, an attorney duly admitted to practice law before the Courts of the
State of New York, affirms the truth of the following under the penalty of perjury:
1. I am an attorney with the law firm of AIDALA, BERTUNA & KAMINS, P.C.,
attorneys for Defendant HARVEY WEINSTEIN (hereinafter referred to as “Weinstein”), in the
above-entitled action, and as such, I am familiar with the facts and circumstances surrounding this
case.
2. I submit this Affirmation in support of Weinstein’s motion, pursuant to CPLR 3211(a)(5)
& (a)(7), for: (a) an order dismissing all the claims set forth in Plaintiff Kaja Sokola’s (“Sokola”)
Complaint (“Complaint”) dated December 19, 2019, in its entirety, with prejudice; and (b) for
such other and further relief as this Court deems just and proper.
3. Attached hereto as EXHIBIT A is a true and correct copy of the Complaint filed by Sokola
in the above-captioned action, dated December 19, 2019 (NYSCEF No. 1).
4. Attached hereto as EXHIBIT B is a true and correct copy of a Notice of Removal that was
filed by Co-Defendant Robert Weinstein in the above-captioned action, dated February 3, 2020
(NYSCEF No. 6).
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FILED: NEW YORK COUNTY CLERK 08/12/2020 10:59 PM INDEX NO. 950250/2019
NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 08/12/2020
5. Attached hereto as EXHIBIT C is a true and correct copy of a Notice of Motion to
Remand, dated March 4, 2020, which was filed by Sokola in Sokola v. Weinstein et al, Case No.,
1:20-cv-00925-LJL, in the United States District Court for the Southern District of New York.
6. Attached hereto as EXHIBIT D is a true and correct copy of a Decision and Order by Hon.
Lewis J. Liman, United States District Judge, dated July 2, 2020, which was filed in Sokola v.
Weinstein et al, Case No., 1:20-cv-00925-LJL, in the United States District Court for the Southern
District of New York.
7. For the reasons set forth in the accompanying Memorandum of Law, Weinstein
respectfully submits that the Court should dismiss the Complaint in its entirety, and with prejudice.
Dated: New York, New York /s/ Imran H. Ansari
August 12, 2020 IMRAN H. ANSARI
2 of 2
Document Filed Date
August 12, 2020
Case Filing Date
December 19, 2019
Category
Torts - Child Victims Act
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FILED: NEW YORK COUNTY CLERK 08/12/2020 10:59 PM INDEX NO. 950250/2019 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 08/12/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK KAJA SOKOLA., Index No.: 950250/2019 Plaintiff, AFFIRMATION OF IMRAN H. ANSARI IN - against - SUPPORT OF MOTION HARVEY WEINSTEIN, ROBERT WEINSTEIN, THE WALT DISNEY COMPANY, DISNEY ENTERPRISES, INC., MIRAMAX HOLDING CORP., MIRAMAX FILM NY LLC f/k/a MIRAMAX FILM CORP., and DOE CORP. 1-10, Defendants. IMRAN H. ANSARI, an attorney duly admitted to practice law before the Courts of the State of New York, affirms the truth of the following under the penalty of perjury: 1. I am an attorney with the law firm of AIDALA, BERTUNA & KAMINS, P.C., attorneys for Defendant HARVEY WEINSTEIN (hereinafter referred to as “Weinstein”), in the above-entitled action, and as such, I am familiar with the facts and circumstances surrounding this case. 2. I submit this Affirmation in support of Weinstein’s motion, pursuant to CPLR 3211(a)(5) & (a)(7), for: (a) an order dismissing all the claims set forth in Plaintiff Kaja Sokola’s (“Sokola”) Complaint (“Complaint”) dated December 19, 2019, in its entirety, with prejudice; and (b) for such other and further relief as this Court deems just and proper. 3. Attached hereto as EXHIBIT A is a true and correct copy of the Complaint filed by Sokola in the above-captioned action, dated December 19, 2019 (NYSCEF No. 1). 4. Attached hereto as EXHIBIT B is a true and correct copy of a Notice of Removal that was filed by Co-Defendant Robert Weinstein in the above-captioned action, dated February 3, 2020 (NYSCEF No. 6). 1 of 2 FILED: NEW YORK COUNTY CLERK 08/12/2020 10:59 PM INDEX NO. 950250/2019 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 08/12/2020 5. Attached hereto as EXHIBIT C is a true and correct copy of a Notice of Motion to Remand, dated March 4, 2020, which was filed by Sokola in Sokola v. Weinstein et al, Case No., 1:20-cv-00925-LJL, in the United States District Court for the Southern District of New York. 6. Attached hereto as EXHIBIT D is a true and correct copy of a Decision and Order by Hon. Lewis J. Liman, United States District Judge, dated July 2, 2020, which was filed in Sokola v. Weinstein et al, Case No., 1:20-cv-00925-LJL, in the United States District Court for the Southern District of New York. 7. For the reasons set forth in the accompanying Memorandum of Law, Weinstein respectfully submits that the Court should dismiss the Complaint in its entirety, and with prejudice. Dated: New York, New York /s/ Imran H. Ansari August 12, 2020 IMRAN H. ANSARI 2 of 2