On September 04, 2018 a
Letter,Correspondence
was filed
involving a dispute between
Gabriella Leal,
Isabella Martinez,
and
Sara Bronfman-Igtet,
for Torts - Other (GBL Sec 349, Class Action)
in the District Court of Kings County.
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COZEN
2 O'CONNOR
March 8, 2019 Rachel Bevans
DirectPhone 212-908-1378
Direct Fax 646-880-3643
VIA ECF
rbevansecozen.com
Honorable Peter P. Sweeney
Supreme Court, Kings County
360 Adams Street, Rm. 761
Brooklyn, NY
Re: Martinez & Leal v. Brontman-Igtet, Index No. 517921/2018
Dear Hon. Sweeney:
On February 4, 2019, during oral argument before the Court on Defendant's Motion to Dismiss,
the Court directed both parties to submit additional briefing by March 11, 2019 on the issue of
whether Plaintiff's counsel's violation of Judiciary Law § 470 is a defect that can be cured by
establishing an office in New York state after the filing of the Complaint.
On February 14, 2019, the Court of Appeals set forth a ruling in Arrowhead Capital Fin., Ltd v
Cheyne Specialty Fin. Fund L.P., 2019 NY Slip Op 01124 ("Arrowhead'). In Arrowhead, the Court
stated that a "party may cure the section 470 violation with the appearance of compliant counsel
counsel."
or an application for admission pro hac vice by appropriate
We await documents from Plaintiff's counsel, such as a New York office lease or notice of
appearance of co-counsel, that establish that he cured his Section 470 violation.
Respectfully Submitted,
COZEN O'CONNOR
By: Rachel Bevans
RB
166 Floor New York, NY 10006
45 Broadway
212.509.9400 800.437.7040 212.509.9492 Fax cozen.com
Document Filed Date
March 08, 2019
Case Filing Date
September 04, 2018
Category
Torts - Other (GBL Sec 349, Class Action)
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COZEN 2 O'CONNOR March 8, 2019 Rachel Bevans DirectPhone 212-908-1378 Direct Fax 646-880-3643 VIA ECF rbevansecozen.com Honorable Peter P. Sweeney Supreme Court, Kings County 360 Adams Street, Rm. 761 Brooklyn, NY Re: Martinez & Leal v. Brontman-Igtet, Index No. 517921/2018 Dear Hon. Sweeney: On February 4, 2019, during oral argument before the Court on Defendant's Motion to Dismiss, the Court directed both parties to submit additional briefing by March 11, 2019 on the issue of whether Plaintiff's counsel's violation of Judiciary Law § 470 is a defect that can be cured by establishing an office in New York state after the filing of the Complaint. On February 14, 2019, the Court of Appeals set forth a ruling in Arrowhead Capital Fin., Ltd v Cheyne Specialty Fin. Fund L.P., 2019 NY Slip Op 01124 ("Arrowhead'). In Arrowhead, the Court stated that a "party may cure the section 470 violation with the appearance of compliant counsel counsel." or an application for admission pro hac vice by appropriate We await documents from Plaintiff's counsel, such as a New York office lease or notice of appearance of co-counsel, that establish that he cured his Section 470 violation. Respectfully Submitted, COZEN O'CONNOR By: Rachel Bevans RB 166 Floor New York, NY 10006 45 Broadway 212.509.9400 800.437.7040 212.509.9492 Fax cozen.com