Motion for Stipulated Judgment in Alla Shimonova Individually, Alla Shimonova as a Guardian of the Personal Needs and Property Management of DANIEL PINKHASOV v. Richard J Santaella, City Of New York, Shannon Epstein, Daniel Epstein, Rego Ii Borrower Llc| Trellis.Law

On September 02, 2016 a Motion-Secondary was filed involving a dispute between Alla Shimonova As A Guardian Of The Personal Needs And Property Management Of Daniel Pinkhasov, Alla Shimonova Individually, and City Of New York, Daniel Epstein, Rego Ii Borrower Llc, Richard J Santaella, Shannon Epstein, for Torts - Other Negligence (Premises Liability) in the District Court of Queens County.

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FILED: QUEENS COUNTY CLERK 04/15/2021 03:07 PM INDEX NO. 710609/2016
NYSCEF DOC. NO. 492 RECEIVED NYSCEF: 04/15/2021

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
--------------------------------------------------------- X
ALLA of (E-File)
SHIMONOVA, Individually and as a Guardian
Index No.: 710609/2016
The Personal Needs and Property Management of
DANIEL PINKHASOV
AFFIRMATION IN SUPPORT OF
MOTION BY ORDER TO SHOW
Plaintiffs
-against- CAUSE TO MODIFY AND/OR
VACATE JUDGMENT

RICHARD J. SANTAELLA, CITY OF NEW
Honorable Justice Joseph J. Esposito
YORK, SHANNON EPSTEIN, DANIEL
EPSTEIN and REGO II BORROWER LLC,

Defendants.
------------------------------------ X

Stephen J. Molinelli, an attorney duly admitted to practice law before the Courts of the

State of New York, affirms the following upon information and belief, under the penalties of

perjury and pursuant to CPLR §2106:

1. I am an attorney at law and Of Counsel to the law firm of Farber Brocks & Zane,

LLP, the attorneys for the defendant Rego II Borrower, LLC (hereinafter "Rego II"). Based upon

a review of the files maintained by this office pertaining to this matter, I am fully familiar with

the facts and circumstances surrounding this action.

2. This Affirmation is respectfully submitted in support of the instant application

seeking an Order: (a) pursuant to CPLR § 5015(a)(5) granting a modification of a prior Judgment

Entered, Filed and Recorded by the Clerk of the County of Queens on March 5, 2020; and/or (b)

pursuant to CPLR § 5015(a)(5) granting a vacatur of the same prior Judgment; (c) and upon such

modification and/or vacatur, granting defendant Rego II leave to file a new Judgment, and upon

such filing,directing the Clerk of the County of Queens to fileand record said Judgment; and,

(d) granting such other and further reliefas this Court may deem jus proper and equitable.

3. A copy of the Judgment Entered, Filed and Recorded by the Clerk of the County

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of Queens on March 15, 2020 addressed by this motion is annexed hereto as Exhibit "A".

4. For the reasons set forth below, it is respectfully submitted that said Judgment

should be modified and/or vacated, and upon such modification or vacatur, that the office of the

undersigned, on behalf of Rego II, be permitted to filea new Judgment correctly recording the

current disposition of the various prior Summary Judgment Motions, and upon such filing

directing the Clerk of the County of Queens to file and record said Judgment.

M_CKGROUND

5. The subject action arises out of an incident alleged to have occurred on Sunday,

September 15, 2013 at approximately 7:10 p.m. involving a motor vehicle-pedestrian knock

97th
down accident which occurred in the north bound lane of Street in the area of the Rego Park

Mall, which was owned and operated by the movant herein, Rego II. More specifically, the

97th
accident occurred in the northbound lane of Street between the Horace Harding Expressway

62nd
to the north and Drive to the south.

97th south-
6. At the time of the occurrence Street WaS a tWO Way north-bound and

bound street with one moving lane in each direction, with adjacent lanes for vehicular parking on

either side of the travel lanes.

97th
7. The plaintiff's decedent, Daniel Pinkasov was struck mid-block on Street

while Mr. Pinkasov was crossing west-bound from the opposite (east) side of the roadway

toward the Rego Park Mall when he was struck by the vehicle owned and operated by defendant

Richard J. Santaella.

8. In addition to the alleged negligence against Mr. Santaella in the operation of his

vehicle, it is alleged that the City of New York was negligent for, among other things, its

roadway design, that defendant Rego II was negligent, among other things, for its failure to

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control foot, pedestrian and vehicluar trafficto and from the Rego Park Mall, and that defendants

Shannon and Daniel Epstein were negligent with respect to their ownership and/or operation of

97th
their vehicle which was double parked adjacent to northbound Street. Mr. Pinkasov emerged

from in front of the Epstein vehicle into the street and was struck by the Santaella vehicle as he

attempted to cross the street.

PROCEDURAL HISTORY

9. In compliance with the condition precedent to the commencement of an action

against the City of New York, plaintiff's counsel filed a Notice of Claim against the City, a copy

of which is annexed hereto as Exhibit "B".

10. The action was commenced by the filing of plaintiff's original Summons and

Complaint on June 9, 2014 naming as defendants, vehicle owner/operator Richard J. Santaella

and the City of New York. Plaintiff filed a Supplemental Summons and Amended Verified

Complaint on or about April 20, 2016 adding defendant Shannon Epstein as party defendant.

Plaintiff also commcñced a separate action by the filing of a Summons and Complaint naming as

defendants Daniel Epstein and Rego II.Copies of plaintiff's original Summons and Complaint,

Supplemental Summons and Amended Verified Complaint in the original action, and plaintiff's

"D"
Summons and Complaint in the latter separate action are annexed hereto as Exhibit "C", and

"E".

11. By So Ordered Stipulation the two actions were eventually consolidated into the

current action with the current Index Number. A copy of the So Ordered Stipulation is annexed

hereto as Exhibit "F".

12. Each of the named defendants joined issue, as addressed in order of the current

caption, below.

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13. Defendant Richard J. Santaella joined issue by service of his Verified Answer to

plaintiff's original Complaint, and subsequently served an Answer to plaintiffs Amended

"G"
Complaint. Copies of Santaella's Answers are annexed hereto as Exhibit and "H".

l 4. The City ofNew York Joined issue by filing of itsVerified Answer to the original

Complaint, and subsequently filed a Verified Answer to the Amended Verified Complaint and a

Verified Amended Answer to the Amended Verified Complaint. Copies of the City's Answers

"J"
are annexed hereto as Exhibits "I", and "K".

15. Defendant Daniel Epstein joined issue by filing of his Verified Answer, and an

Amended Answer was subsequently filed on behalf of both Shannon and Daniel Epstein. Copies

Defendants'
of the Epstein Verified Answer and Amended Answer are annexed hereto as

"L"
Exhibits and "M".

16. Issue was joined by Rego II by service of its Verified Answer, and Rego

subsequently filed an Amended Verified Answer, copies of which are annexed hereto as Exhibit

"N"
and Exhibit "O".

PRIOR SUMMARY JUDGMENT MOTION HISTORY

17. Defendants Shannon Epstein and Daniel Epstein moved for an Order pursuant to

CPLR §3212 seeking summary judgment dismissing plaintiff's Complaint and further dismissing

allCross Claims against them (Motion Sequence No. 6).

18. Defendant Rego II moved for an Order pursuant to CPLR §3212 and CPLR

Article 16, seeking summary judgment dismissing plaintiff's Complaint and further dismissing

allCross Claims against Rego II (Motion Sequence No. 7).

19. The City of New York moved before this Court pursuant to CPLR §3211 and

CPLR §3212 seeking summary judgment dismissing the Amended Verified Complaint and

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further dismissing allCross Claims against the City (Motion Sequence No. 8).

20. Defendant Richard J. Santaella moved before this Court pursuant to CPLR §3212

seeking summary judgment dismissing the plaintiff's Complaint against him (Motion Sequence

No. 9).

ORIGINAL DECISION AND ORDER

21. This Court, by Honorable Justice Joseph J. Esposito, combined the four (4)

motions for disposition and determination, and issued a single Short Form Order dated January

21, 2020. As that Short Form Order was then filed separately by the Clerk's office for each

motion sequence (Nos. 6, 7, 8 and 9; ECF Documents Nos. 400, 401, 402 and 403), copies of

"P"
those four filed Short Form Orders are annexed hereto collectively as Exhibit (the ECF

Document Number for each is indicated by the Clerk's office in the upper left-hand corner of

each document).

22. Said Decision and Order disposed of the motions above as follows:

• Motion Sequence No. the motion of defendants Shannon Epstein and
6-Granting

Daniel Epstein dismissing plaintiff's Complaint against them.

• Motion Sequence No. 7-Granting the motion of defendant Rego II,dismissing

plaintiff's Complaint against it with prejudice and further dismissing all Cross

Claims against itwith prejudice.

• Motion Sequence No. 8-Granting the motion of defendant City of New York

dismissing plaintiff's Complaint against the City.

• Motion Sequence No. 9-Granting the motion of defendant Richard J. Santaella

dismissing plaintiff's Complaint against him.

Exhibit "P".

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ORIGINAL JUDGMENT

23. Following the disposition of the multiple summary judgment motions, above, a

Judgment was submitted for settlement by counsel representing the City of New York, and the

Judgment thereafter was Filed and Recorded by the Clerk of the County of Queens on March 5,

2020. Exhibit "A".

24. The original Judgment correctly reflects the disposition of the Summary Judgment

Motions of defendants Shannon Epstein and Daniel Epstein (Motion Sequence No. 6), the City

of New York (Motion Sequence No. 8) and defendant Richard J. Santaella (Motion Sequence

No. 9).Exhibit "A".

25. The original Judgment, in part, incorrectly records the disposition of the summary

judgment motion of defendant Rego II. The Judgment correctly reflects only so much of the

Short Form Order whereby that branch of Rego II's summary judgment motion seeking

dismissal of plaintiff's Complaint against Rego II was granted with prejudice. Exhibit "A".

26. However, the original Judgment incorrectly failed to include the disposition in the

Short Form Order of so much of Rego II's motion dismissing the cross claims asserted against

Rego II. Exhibit "A".

27. The Short Form Order recites Judge Esposito's determination of that branch of

Rego II's motion as follows:

"The branch of the motion which is to tiismiss the claims for c::::::::::-law and
cüütrüctual indemnity and contribution is also granted. The City and Santaella
asserted cross claims against all defendants for contribution, common-law

indemnity and contractual indemnity. The Epstein defendant also asserted cross
claims against all defendants for contribution and or common-law
indemnification. On the instant facts, Rego II owed plaintiffs no duty of care as
itpertains to preventing the instant accident, and without a duty, there can be no

liability for contribution or indemnification (see Nassau Roofing & Sheet Metal
Co. v Facilities Dev. Corp., 71 NY2d 599, 603 [1988]; Smith v Hooker
Chemical Corp., 83 AD2d 199, 201-202 [4th Dept. 1981), ly. dismissed 56

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[19821)." 8."
NY2d 503 (emphasis provided). Exhibit "Q", at pages 7 to

Exhibit "P".

28. The Judgment should also have entered Judgment in favor of Rego II dismissing

allcross claims against itwith prejudice.

SUBSEOUENT MOTION PRACTICE

29. After the entry of the original Jüdgment, plaintiff Shiminova filed a motion to

reargue (Motion Sequence No.: 10). Plaintiff's motion sought re-argument of the summary

judgment motions of: Shannon Epstein and Daniel Epstein (Motion Sequence No. 6); the City of

New York (Motion Sequence No. 8); and defendant Richard J. Santaella (Motion Sequence No.

9).

30. Plaintiff's motion to reargue did not seek re-argument of Rego II's summary

judgment motion (Motion Sequence No. 7).

31. This Court, by Honorable Joseph J. Esposito, issued a further Short Form Order

dated October 2, 2020 and filed on October 5, 2020, granting plaintiff re-argument of the prior

summary judgment motions of defendants Shannon and Daniel Epstein (Motion Sequence No.

6), the City of New York (Motion Sequence No. 8) and Richard J. Santaella (Motion Sequence

No. 9). A copy of the re-argument Short Form Order is annexed hereto as Exhibit "Q".

32. Upon re-argument of the said motions, Justice Esposito's Short Form Order

denied the summary judgment motions of Shannon and Daniel Epstein (Motion Sequence No. 6),

the City of New York (Motion Sequence No. 8), and Richard J. Santaella (Motion Sequence No.

9). Exhibit "Q".

33. Thus, the original Judgment (Exhibit "A") has been rendered additionally

incorrect, insofar as it enters Judgment dismissing plaintiff's Complaint against defendants

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Shannon and Daniel Epstein, the City of New York, and Richard J. Santaella, where, in fact,the

summary judgment motions of each of those defendants have been denied.

ATTEMPTS TO FILE CORRECTED JUDGMENT: SUBMISSIONS OF

PROPOSED AMENDED JUDGMENTS

34. Recognizing that the original Judgment was initially incorrect in that it failed to

enter Judgment on behalf of Rego II dismissing the Cross Claims against Rego II (it correctly

dismissed plaintiff's Complaint against Rego II), and since the Short Form Order disposing of

the plaintiff's motion to reargue rendered the original Judgment additionally incorrect, the office

of the undersigned first attempted to correct the original Judgment by the filing a Notice of

Settlement of an Amended Proposed Judgment, together with the Proposed Judgment, Copies of

which are annexed hereto as Exhibit "R".

35. The Proposed Judgment was noticed for settlement on December 9, 2020. Exhibit

36. A copy of the ECF Notice of Confirmation of Filing, together with the ECF

Notice that the Proposed Amended Judgment was Noticed for Settlement on December 9, 2020

"S"
are annexed hereto as Exhibits and "T", respectively.

37. In addition to including a provision in the Proposed Judgment to correct the

original Judgment to reflect the grant of summary judgment to Rego II dismissing with prejudice

the cross-claims asserted against Rego II (in accordance with the Short Form Order dated

January 21, 2020, Exhibit "P"), the Proposed Judgment also included provisions vacating the

entry of judgment on behalf of defendants Sharon and Daniel Epstein, the City of New York and

Richard J. Santaella (in accordance with the Short Form Order dated October 2, 2020, Exhibit

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38. On the noticed settlement date, December 9, 2020, the Queens County Clerk filed

a notification (a copy of which is annexed as Exhibit "U") returning the Proposed Judgment "for

Returning"
correction", stating the "Reason for as:

"Clerk has no authorization to enter judgment as presented. The Court has to

Order the vacatur of the previously filed judgment. The Order entered 10/5/20

#432)."
(Doc #452) does not vacate the judgment entered 3/5/20 (Doc Exhibit

"U".

39. To correct that issue in accordance with that notification, the office of the

undersigned filed a second Notice of Proposed Judgment and Proposed Judgment on February

19, 2020, copies of which are annexed hereto as Exhibit "V".

40. In accordance with that notification, the second Proposed Judgment (Exhibit "V")

did not include the provisions vacating the entry of judgment on behalf of defendants Shanon

and Daniel Epstein, the City of New York and Richard J. Santaella, and only sought a correction

of the original Judgment to reflect the grant of summary judgment to Rego II dismissing with

prejudice the cross-claims asserted against Rego II (in accordance with the Short Form Order

dated January 21, 2020, Exhibit "P"),

41. The Proposed Judgment was noticed for settlement on December 9, 2020.

(Exhibit "V").

42. A copy of the ECF Notice of Confirmation of Filing, together with the ECF

Notice that the Proposed Amended Judgment was Noticed for Settlement on March 15, 2021 are

"W"
annexed hereto as Exhibits and "X", respectively.

43. On the noticed settlement date, March 15, 2021, the Queens County Clerk filed a

notification (a copy of which is annexed as Exhibit "Y") returning the second Proposed

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Returning"
Judgment "for correction", stating the "Reason for as:

"The Judgment Presented cannot be Entered since the one that has already been

stands."
filed (Doc. #432) still Exhibit "Y".

NECESSITY FOR COURT ORDER GRANTING THIS MOTION

44. Based upon the forgoing, an amended, corrected, or new Judgment cannot be

entered without further Order of this Court, as the original Judgment "still stands".

45. Without further Court Order a Judgment cannot be entered correctly reflecting the

disposition of Rego II's summary judgment motion, including both summary judgment and

dismissal of plaintiff's Complaint against Rego II,and summary judgment and dismissal of the

Cross Claims against Rego II. (in accordance with the Short Form Order dated January 21, 2020,

Exhibit "P").

46. Without further Court Order a Judgment also cannot be entered correctly

reflecting the disposition of the summary judgment motions of defendants Shannon and Daniel

Epstein (Motion Sequence No. 6), the City of New York, (Motion Sequence No. 8) and Richard

J. Santaella (Motion Sequence No. 9), which have been denied (in accordance with the Short

Form Order dated October 2, 2020, Exhibit "Q").

47. In fact, the original Judgment (Exhibit "A"), grants those defendants Judgment,

whereas the Short Form Order dated January 20, 2021(Exhibit "Q"), upon re-argument, denies

summary judgment as to those defendants.

48. As such, the instant application pursuant to CPLR §5015(a)(5) is necessary to

modify the original Judgment or vacate itall together so that a new Judgment correctly reflecting

the disposition of the several summary judgment motions including the grant of both branches of

Rego II's motion judgment plaintiff's Complaint and cross-
(summary dismissing dismissing

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claims).

CPLR § 5015(aK51

49. CPLR § 5015(a)(5) entitled "Relief from Judgment or Order", in pertinent part

states as follows:

"(a) On Motion. The Court which rendered a

Judgment or Order may relieve a party from itupon

such terms as may be just, on motion of any

interested person with such notice as the Court may

direct, upon the ground of:

"(5) Reversal, modification or vacatur of a prior

based."
Judgment or Order upon which itis

50. Under CPLR §5015(a), a Court is empowered to vacate a default Judgment for

several reasons, including excusable neglect, newly discovered evidence, fraud,

misrepresentation, or other misconduct by an adverse party, lack of jurisdiction, or upon the

reversal, modification or vacatur of a prior Order. These categories represent the codification of

the principal grounds upon which the Courts have traditionally vacated Judgments as part of their

"inherent discretionary power". Woodson v. Mendon Leasing Corporation, 100 NY2d 62, 760

NYS 2d 727 (2003), citing Siegel, Practice Commentaries, McKinneys Cons Laws of NY, Book

7B, CPLR C5015:11, at 476 (1992).

51. In Woodson, the Court of Appeals continued that "in addition to the grounds set

forth in section 5015(a), a Court may vacate itsown Judgment for sufficient reason and in the

interest of substantial justice. Id. Citing, Ladd v. Stevenson, 112 NY 325, 332 (1889), see

generally 10 Weinstein-Korn-Miller, NY Civ. Prac. Paragraph 5015.01, at 50-299; Paragraph

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5015.12 at 50-338 (2002).

52. Woodson continues. "as one commentator has noted, "It might have been more

elegant to add an additional paragraph to CPLR § 5015(a) as a kind of catch all category... but

the intent seems clear enough without it".Quoting Siegel, Practice Commentaries, McKinneys

Cons Laws of NY, Book 7B, CPLR §C5015:11, at 476-477.

53. Based upon the Short Form Order dated October 2, 2020 (Exhibit "R"), the

original Judgment, granting judgment and dismissal of plaintiff's Complaint to defendants

Shannon and Daniel Epstein, the City of New York and Richard J. Santaella have in essence

Judgment"
already been vacated. CPLR § 5015(a)(5). Thus, the "dependent can similarly be

canceled or adjusted. Siegel, Practice Commentaries, McKinneys Cons. Laws of NY Book 7B,

CPLR §C5015:11, at 476 (1992), Chapter 16, §431.

54. As stated by Professor Seigel "where an earlier Judgment has been vacated,

reversed or otherwise undone, itis of course divested of itsfinality...". Siegel, NY Practice § 444

(5"'
at 776 ed. 2011) (emphasis implied), citing CPLR §5015(a)(5). See also, Nash v. The Port

Authority of New York and New Jersey, 22 NY2d 220, 980 NYS 2d 880 (2013).

55. CPLR §5015 applies not only to judgments that are stillin the appellate process,

but also those to which appellate review has been exhausted. Nash, Id. "[S]ave for the one-year

requirement in §5015(a)(1) concerning excusable defaults, motions made pursuant to paragraphs

(2), (3), and (5) contain no limitation in time, only a requirement that the time within the motion

is made be "reasonable". Nash, Id., citing, Siegel, Practice Commentaries, McKinneys Cons.

Laws of NY, Book 7B, CPLR §C5015:3.

56. The determination as to whether such a motion has been made within a reasonable

time is within the motion Court's discretion. See, Nash, Id., citing Third Preliminary Rep. of

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Advisory Comm. On Prac. and Pro., 1959 Legis. Doc. No. 17 at 205.

57. Notably, §5015 does not distinguish between final and non-final Judgments, or

those that have or have not exhausted the appeals process. Nash, Id

58. It is respectfully submitted that the instant application is being made within a

reasonable time not only from the entry of the Short Form Orders dated January 21, 2020 and

"S"
October 2, 2020 (Exhibits and "R"), but also within a reasonable time of the recording and

filing of the original Judgment (Exhibit "A"). Especially since the office of the undersigned

made two (2) prior attempts to file amended Judgments to correct the actual disposition of the

"R"
several summary judgment motions. (see Exhibits through "Y").

CONCLUSIONS

59. Based upon the foregoing, itis respectfully submitted that the current original

Judgment (Exhibit "A") is incorrect and should be modified or vacated pursuant to CPLR

§5015(a)(5) and that Rego II should be permitted to filea new Judgment to correctly reflect the

disposition of the multiple summary judgment motions.

60. Considering both the January 21, 2020 Short Form Order (Exhibit "Q") and the

October 2, 2020 Short Form Order (Exhibit "Q"), the motions were, in fact, disposed of, decided,

and determined as follows:

• Motion Sequence No. the motion of defendants Shannon
6-Denying

Epstein and Daniel Epstein seeking summary judgment dismissing

plaintiff'sComplaint against them.

• Motion Sequence No. the motion of defendant Rego II,
7-Granting

granting Rego II summary judgment dismissing plaintiff's Complaint

against Rego II in itsentirety and with prejudice and further granting

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Rego II summary judgment dismissing all Cross Claims against Rego

II intheir entirety and with prejudice.

• Motion Sequence No. the motion of defendant of
8-Denying City

New York seeking summary judgment dismissing plaintiff's

Complaint against the City.

• Motion Sequence No. the motion of defendant Richard J.
9-Denying

Santaella seeking summary judgment dismissing plaintiff's

Complaint against him.

61. It isfurther submitted that the Court should permit Rego II to enter a Judgment as

proposed in the form and substance set forth in the annexed proposed Judgment (Exhibit "Z"), or

in such other form and substance as the Court directs to correctly reflect the grant of summary

judgment to Rego II dismissing plaintiff's Complaint against Rego II in its entirety and with

prejudice and further granting Rego II summary judgment dismissing all Cross Claims against

Rego II in their entirety and with prejudice, and removing the adjudgments entering judgment in

favor of defendants Shanon Epstein, Daniel Epstein, The City of New York and Richard J.

Santaella.

62. Finally, itis submitted that the Clerk should be directed to Enter, File and Record

said Judgment.

Dated: Garden City, New York
April 15, 2021

STEPHEN J MOLINELLI

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Case Info

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Tracy A Track Judge’s New Case

Case No.

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Document Filed Date

April 15, 2021

Case Filing Date

September 02, 2016

County

Parties

(2014-027247) Attorney for the Defendant
Alla Shimonova as a Guardian of the Personal Needs and Property Management of DANIEL PINKHASOV Plaintiff
Alla Shimonova Individually Plaintiff
AL-SULLAMI, YAMILE R. Attorney for the Defendant
BROWNING, EMMA ELIZABETH Attorney for the Defendant
CAFARO, CHRISTOPHER THOMAS Attorney for the Defendant
CITY OF NEW YORK Defendant
COYLE, MAGDA D Attorney for the Defendant
Daniel Epstein Defendant
FINNING, PETER E Attorney for the Defendant
FINNING, PETER E. Attorney for the Defendant
FUNK, ANDREW J Attorney for the Defendant
GOTTLIEB, ANNA WOLONCIEJ Attorney for the Defendant
GRAMLICH, DANIEL CHRISTIAN Attorney for the Defendant
GREENIDGE, JEREL TRISTAN Attorney for the Defendant
GROSS, ELIZABETH DALE Attorney for the Defendant
JACOBS, BENJAMIN P Attorney for the Plaintiff
MOLINELLI, STEPHEN J Attorney for the Defendant
MONTFORT HEALY MCGUIRE & SALLEY Attorney for the Defendant
REGO II BORROWER LLC Defendant
Richard J Santaella Defendant
RUBIN, TODD MITCHELL Attorney for the Plaintiff
Shannon Epstein Defendant
The Law Office of Michael Ferro & Associates Attorney for the Defendant
TOSCA, ERIC P. Attorney for the Defendant
WISSEMANN, HILARY MADELINE Attorney for the Defendant
ERIC POMERANTZ Attorney
ARTHUR SIMURO Attorney
ZACHARY CARTER Attorneys for Defendants
JAMES JOHNSON Attorneys for Defendants
SALLY MAIOLO Attorney
JENNIFER KARRMANN-GRANAI Attorneys for Defendants
MICHAEL MADDALONI Attorney
STUART FINZ Attorney
EVAN FEUERSTEIN Attorney
JOHN MAZZARO Attorney
WILLIAM PETERSON Attorney
ELIZABETH SCHAEFER Attorney
LEONARD FINZ Attorney
JONNY FRANK Attorney
JOHN MOLINELLI Attorney
WARWICK CARTER Attorney
NORMAN MARCUS Attorney
CHARLES LOEB Attorney
DEBRA SILBER Attorney
ASHLEY PAPPAS Attorney
JAMIE GREENFIELD Attorney
PAULINA PROCHOWNIK Attorneys for Defendants
ANDREW FRANK Attorney
JASON FUNK Attorneys for Defendants
TODD MEADOW Attorneys for Plaintiffs
TERENCE KEMP Attorney
PETER FIELDS Attorneys for Defendants
MAX RUBIN Attorney
LONNIE MENDOLIA Attorney
TED MITCHELL Attorney
HILLARY WEISMAN Attorneys for Defendants
STUART LEWINE Attorney

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Motion-Secondary: Alla Shimonova Individually, Alla Shimonova as a Guardian of the Personal Needs and Property Management of DANIEL PINKHASOV v. Richard J Santaella, City Of New York, Shannon Epstein, Daniel Epstein, Rego Ii Borrower Llc

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