On May 11, 2018 a
Motion,Ex Parte
was filed
involving a dispute between
Stella Stolper,
and
Zarina Burbacki,
for Commercial Division
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 07/02/2018 07:24 PM INDEX NO. 652352/2018
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 07/02/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
--------------------------------------------------------------------X
WIKKED ENTERTAINMENT, INC., and
STELLA STOLPER,
NOTICE OF MOTION
Plaintiffs,
Motion Sequence No. 1
-vs-
Index No. 652352/2018
ZARINA BURBACKI and YONATAN Justice Assigned:
SHIMRONY,
Defendants.
X
--------------------------------------------------------------------X
PLEASE TAKE NOTICE that upon the Affirmation of Jonathan E. Neuman,
Esq., dated July 1, 2018, and the exhibits thereto, the accompanying Memorandum of
Law, and upon all of the pleadings and proceedings heretofore had herein, Defendants
will move this Court, at the courthouse located at 60 Centre Street, New York, New
23"1
York, in the Motion Submission Part Courtroom Room 130, on the day of July,
o'
2018, at 9:30 clock in the forenoon of that day or as soon thereafter as counsel can be
heard, for an Order directing the following relief:
Plaintiffs'
1) Pursuant to N.Y. C.P.L.R. §3211(a)(1) and (a)(7), dismissing Plaintiffs
complaint in its entirety; and
2) Pursuant to 22 NYCRR 130-1.1, awarding $10,000 in attorney's fees to
Plaintiffs'
Defendants for frivolous conduct in asserting numerous false
material factual statements;
together with such other and further relief as this Court deems appropriate under the
circumstances.
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FILED: NEW YORK COUNTY CLERK 07/02/2018 07:24 PM INDEX NO. 652352/2018
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 07/02/2018
The above entitled action is for conversion, tortious interference, breach of
fiduciary duty, unjust enrichment, defamation, violation of 18 U.S.C. 2701 et seq.,
violation of Cal. Penal. Code § 630 et seq., California common law invasion of privacy,
accounting, and legal malpractice.
Pursuant to N.Y. C.P.L.R. 2214(b), answering papers, if any, are required to be
served upon the undersigned at least seven (7) days before the return date of this motion.
Dated: Fresh Meadows, New York
July 2, 2018
Respectfully submitted,
/Jonathan E. Neuman/
JONATHAN E. NEUMAN, ESQ.
Attorney for Defendants
176-25 Union Turnpike, Suite 230
Fresh Meadows, New York 11366
(347) 450-6710
(718) 228-3689 (fax)
jnesq@jenesqlaw.com
TO: Marlen Kruzhkov, Esq.
Kruzhkov Russo PLLC
Attorneys for Plaintiffs
350 Fifth Avenue, Suite 7230
New York, New York 10118
(212) 363-2000
(917) 591-7175 (fax)
marlen@kruzhkovrusso.corn
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Document Filed Date
July 02, 2018
Case Filing Date
May 11, 2018
Category
Commercial Division
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Preview
FILED: NEW YORK COUNTY CLERK 07/02/2018 07:24 PM INDEX NO. 652352/2018 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 07/02/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK --------------------------------------------------------------------X WIKKED ENTERTAINMENT, INC., and STELLA STOLPER, NOTICE OF MOTION Plaintiffs, Motion Sequence No. 1 -vs- Index No. 652352/2018 ZARINA BURBACKI and YONATAN Justice Assigned: SHIMRONY, Defendants. X --------------------------------------------------------------------X PLEASE TAKE NOTICE that upon the Affirmation of Jonathan E. Neuman, Esq., dated July 1, 2018, and the exhibits thereto, the accompanying Memorandum of Law, and upon all of the pleadings and proceedings heretofore had herein, Defendants will move this Court, at the courthouse located at 60 Centre Street, New York, New 23"1 York, in the Motion Submission Part Courtroom Room 130, on the day of July, o' 2018, at 9:30 clock in the forenoon of that day or as soon thereafter as counsel can be heard, for an Order directing the following relief: Plaintiffs' 1) Pursuant to N.Y. C.P.L.R. §3211(a)(1) and (a)(7), dismissing Plaintiffs complaint in its entirety; and 2) Pursuant to 22 NYCRR 130-1.1, awarding $10,000 in attorney's fees to Plaintiffs' Defendants for frivolous conduct in asserting numerous false material factual statements; together with such other and further relief as this Court deems appropriate under the circumstances. 1 of 2 FILED: NEW YORK COUNTY CLERK 07/02/2018 07:24 PM INDEX NO. 652352/2018 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 07/02/2018 The above entitled action is for conversion, tortious interference, breach of fiduciary duty, unjust enrichment, defamation, violation of 18 U.S.C. 2701 et seq., violation of Cal. Penal. Code § 630 et seq., California common law invasion of privacy, accounting, and legal malpractice. Pursuant to N.Y. C.P.L.R. 2214(b), answering papers, if any, are required to be served upon the undersigned at least seven (7) days before the return date of this motion. Dated: Fresh Meadows, New York July 2, 2018 Respectfully submitted, /Jonathan E. Neuman/ JONATHAN E. NEUMAN, ESQ. Attorney for Defendants 176-25 Union Turnpike, Suite 230 Fresh Meadows, New York 11366 (347) 450-6710 (718) 228-3689 (fax) jnesq@jenesqlaw.com TO: Marlen Kruzhkov, Esq. Kruzhkov Russo PLLC Attorneys for Plaintiffs 350 Fifth Avenue, Suite 7230 New York, New York 10118 (212) 363-2000 (917) 591-7175 (fax) marlen@kruzhkovrusso.corn 2 of 2