Motion-Secondary: Stella Stolper v. Zarina Burbacki

On May 11, 2018 a Motion-Secondary was filed involving a dispute between Stella Stolper, and Zarina Burbacki, for Commercial Division in the District Court of New York County.

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FILED: NEW YORK COUNTY CLERK 03/25/2019 05:22 PM INDEX NO. 652352/2018
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Marlen Kruzhkov, Esq.
Kruzhkov Russo PLLC
350 Fifth Avenue, Suite 7230
New York, New York 10118
Tel: (212) 363-2000
Fax: (917) 591-7175

Attorneys for Plaintiff Stella Stolper

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK

STELLA STOLPER,
Index No. 652352/2018
Plaintiff,
v. (Motion Seq. 002)

ZARINA BURBACKI, Hon. Andrew S. Borrok

Defendant. Oral Argument Requested

PLAINTIFF’S MEMORANDUM OF LAW IN SUPPORT OF HER
MOTION TO DISMISS COUNTERCLAIMS

Plaintiff Stella Stolper, by and through her undersigned counsel, respectfully submits this

Memorandum of Law in support of her (i) motion to dismiss the second through fourth

counterclaims set forth against her in the Verified Answer and Counterclaims pursuant to CPLR

§§ 3211(a)(7) and 3016(a), and (ii) motion for a more definite statement pursuant to CPLR §

3024 in regard to the first counterclaim set forth against her in the VAC.

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Table of Contents

TABLE OF AUTHORITIES .......................................................................................................... ii

PRELIMINARY STATEMENT .................................................................................................... 1

FACTS ............................................................................................................................................ 1

ARGUMENT .................................................................................................................................. 2

A. Motion to Dismiss Standard................................................................................................. 2

B. There Is No Common Law Cause of Action for Hostile Work Environment ..................... 3

C. Defamation Is Not Pleaded with The Required Specificity ................................................. 3

D. Tortious Interference Counterclaim is Duplicative.............................................................. 6

E. Defendant Fails to Plead the Elements of Unjust Enrichment/Quantum Meruit ................. 8

CONCLUSION ............................................................................................................................. 10

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TABLE OF AUTHORITIES

Cases

Arvanitakis v. Lester,
145 A.D.3d 650, 44 N.Y.S.3d 71 (2d Dep’t 2016) ..................................................................... 4

AVGraphics, Inc. v. NYSE Grp., Inc.,
22 Misc. 3d 1139(A), 881 N.Y.S.2d 361 (Sup. Ct. 2009) .......................................................... 4

Cowles v. Minicucci,
1 A.D.3d 1060, 767 N.Y.S.2d 746 (4th Dep’t) ........................................................................... 9

Deer Consumer Prod., Inc. v. Little Grp.,
37 Misc. 3d 1224(A), 961 N.Y.S.2d 357 (Sup. Ct. N.Y. Cty 2012) ........................................... 8

European Art Assocs., Inc. v. Trend Galleries, Inc.,
227 A.D.2d 170, 641 N.Y.S.2d 835 (1996) ................................................................................ 9

Fulbright & Jaworski, LLP v. Carucci,
63 A.D.3d 487, (1st Dep’t 2009) ................................................................................................ 9

G.K.A. Beverage Corp. v. Honickman,
55 F.3d 762 (2d Cir. 1995).......................................................................................................... 6

Gill v. Pathmark Stores, Inc.,
237 A.D.2d 563, 655 N.Y.S.2d 623 (2d Dep’t 1997) ................................................................. 5

Goldman v. Barrett,
No. 15 CIV. 9223 (PGG), 2017 WL 4334011 (S.D.N.Y. July 25, 2017) ................................... 7

Kliebert v. McKoan,
228 A.D.2d 232 (1st Dep’t 1996) ............................................................................................... 2

Lanzi v. Brooks,
43 N.Y.2d 778 (1977) ................................................................................................................. 2

Lesesne v. Brimecome,
918 F. Supp. 2d 221 (S.D.N.Y. 2013)......................................................................................... 7

Manas v. VMS Assocs., LLC,
53 A.D.3d 451, 863 N.Y.S.2d 4 (2008) .............................................................................. 2, 4, 5

McCoy v. Admiral Metal Prod. Co.,
160 N.Y.S.2d 961 (App. Term 1st Dep’t 1957) (reversing ........................................................ 9

Men Women NY Model Mgmt., Inc. v. Ford Models, Inc.,
32 Misc. 3d 1236(A), 938 N.Y.S.2d 228 (Sup. Ct. 2011) ...................................................... 6, 7

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Poller v. Washington Square War Veterans, Inc.,
No. 102049-03, 2004 WL 6042632 (Sup. Ct. N.Y. Cty Aug. 5, 2004) ...................................... 2

Ripka v. City of Madison,
80 N.Y.S.3d 479 (3d Dep’t 2018) ............................................................................................... 6

Rosenberg v. Home Box Office, Inc.,
33 A.D.3d 550, 822 N.Y.S.2d 921 (1st Dep’t 2006) .................................................................. 5

Savitt v. Estate of Passantino,
41 Misc. 3d 1219(A) (Sup. Ct. N.Y. Cty 2013) .......................................................................... 2

Singerman v. Reyes,
240 A.D.2d 335, 659 N.Y.S.2d 762 (1997) ................................................................................ 9

Soumayah v. Minnelli,
41 A.D.3d 390, 839 N.Y.S.2d 79 (2007) .................................................................................... 8

Stephan v. Cawley,
24 Misc. 3d 1204(A), 890 N.Y.S.2d 371 (Sup. Ct. 2009) ...................................................... 2, 4

Stern v. Burkle,
20 Misc. 3d 1101(A), 867 N.Y.S.2d 20 (Sup. Ct. 2008) ............................................................ 7

Villacorta v. Saks Inc.,
32 Misc. 3d 1203(A), 932 N.Y.S.2d 764 (Sup. Ct. N.Y. Cty 2011) ........................................... 5

Statutes

N.Y. Exec. Law § 290 (McKinney) ................................................................................................ 2

Rules

CPLR 3013...................................................................................................................................... 2

CPLR 3016............................................................................................................................. passim

CPLR § 3024............................................................................................................................... 1, 2

CPLR §§ 3211......................................................................................................................... 1, 2, 4

Other Authorities

18 N.Y. Jur. 2d Civil Rights § 48 ................................................................................................... 2

NYC Code § 8-102(5) ..................................................................................................................... 2

iii

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PRELIMINARY STATEMENT

The Verified Answer and Counterclaims (“VAC”) is deficient in a variety of ways. It

sets forth a counterclaim for “hostile work environment” but there is no common law claim for

hostile work environment. The defamation counterclaim fails to meet the heightened pleading

standards of CPLR 3016(a) because Defendant Zarina Burbacki (“Defendant”) fails to set forth

the specific words allegedly spoken by Plaintiff Stella Stolper (“Stolper”), to whom such words

were allegedly spoken, and who MC 1 actually is. The tortious interference counterclaim fails

because, since it is wholly based upon Stolper’s alleged defamatory statements, it is nothing

more than a clear attempt to dress up the deficient counterclaim for defamation as a different

counterclaim. Nor does the counterclaim actually identify the business relationship with which

Stolper allegedly interfered. Finally, Defendant’s counterclaim for unjust enrichment/quantum

meruit fails because Defendant does not identify the work she allegedly performed that forms the

basis of this counterclaim. “Personal work” is a phrase without any meaning and does nothing to

communicate the type of work that Defendant allegedly performed on behalf of Stolper.

FACTS 2

Defendant Zarina Burbacki alleges that she “began working” for an individual she labels

“MC.” (VAC ¶ 125). As part of her responsibilities, Defendant had to work with Stolper.

(VAC ¶ 126). Allegedly, Stolper committed various acts that Defendant claims created a hostile

work environment. (VAC ¶¶ 127-158). In addition, Defendant alleges that Stolper defamed

Defendant by making statements to “various individuals” and to “a number of Defendant’s

1
Throughout the VAC, Defendant refers to an individual by the letters “MC,” but does not otherwise identify this
person.
2
The VAC contains numerous allegations pertaining to non-party Yonatan Shimrony (“Shimrony”). Since
Shimrony is not a party to this action (he is neither a defendant nor plaintiff nor counterclaimant), none of these
allegations have any place in the VAC whatsoever and must be stricken from the VAC. Certainly, they should not
be considered relevant allegations for purposes of this motion to dismiss.

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colleagues and to other professionals in the entertainment industry and beyond.” (VAC ¶¶ 162,

165). Defendant also alleges that she performed “personal work” on behalf of Stolper and was

not compensated for such “personal work.” (VAC ¶ 178).

ARGUMENT

A. Motion to Dismiss Standard

On a motion to dismiss pursuant to CPLR § 3211(a)(7) for failure to state a cause of

action, the facts pleaded are taken as true and accorded every favorable inference. Kliebert v.

McKoan, 228 A.D.2d 232 (1st Dep’t 1996). However, bare legal conclusions are not accorded

every favorable inference. Poller v. Washington Square War Veterans, Inc., No. 102049-03,

2004 WL 6042632 (Sup. Ct. N.Y. Cty Aug. 5, 2004).

“A motion to dismiss the complaint for failure to state a cause of action will generally

depend upon whether or not there was substantial compliance with CPLR 3013. If the allegations

are not ‘sufficiently particular to give the court and parties notice of the transactions or occurrences

intended to be proved and the material elements of each cause of action,’ the cause of action will

be dismissed.” Savitt v. Estate of Passantino, 41 Misc. 3d 1219(A) (Sup. Ct. N.Y. Cty 2013).

A cause of action for defamation must meet the heightened pleading standard set forth in

CPLR 3016(a). Manas v. VMS Assocs., LLC, 53 A.D.3d 451, 454, 863 N.Y.S.2d 4, 8 (2008);

Lanzi v. Brooks, 43 N.Y.2d 778, 780 (1977); CPLR 3016(b); Stephan v. Cawley, 24 Misc. 3d

1204(A), 890 N.Y.S.2d 371 (Sup. Ct. 2009).

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B. There Is No Common Law Cause of Action for Hostile Work Environment

There is no common law cause of action in New York State for hostile work

environment. 3 Pursuant to CPLR § 3024, “[i]f a pleading is so vague or ambiguous that a party

cannot reasonably be required to frame a response he may move for a more definite statement.”

The motion for a more definite statement should be granted in regard to the first counterclaim

because it is unclear what legal claim Defendant’s cause of action for “hostile work

environment” relates to, and Stolper should not have the burden of guessing the common law or

statutory grounds upon which this counterclaim is based.

Additionally, the motion for a more definite statement should be granted because

Defendant fails to properly identify the individual listed in the VAC as “MC.” Stolper cannot

properly respond to this counterclaim without knowing which individual she allegedly was

working for when her alleged improper behavior occurred.

Nor does Defendant ever identify her job title or the work she performed for MC. Stolper

cannot properly respond to this counterclaim without knowing what job and/or work Defendant

was performing when she allegedly worked with Stolper.

C. Defamation Is Not Pleaded with The Required Specificity

The defamation counterclaim must be dismissed because it fails to meet the heighted

pleading standard pursuant to CPLR § 3016(a) due to Defendant’s failure to set forth the specific

3
If Defendant’s counterclaim for hostile work environment is based upon federal (Title VII), New York State (N.Y.
Exec. Law § 290 (McKinney)) and/or New York City (NYC Code § 8-102(5)) Human Rights Law, it would likely
fail because there is no employer/employee relationship alleged; Defendant only alleges that she was hired “by
Plaintiff . . . to work for the benefit of MC and her corporate entities.” (VAC ¶ 177); 18 N.Y. Jur. 2d Civil Rights §
48 (“It is axiomatic that in order for one to be held liable for employment discrimination under New York law, there
must have existed between the parties, at the time of the action complained of, the relationship of employer and
actual or prospective employee.”).

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individuals that allegedly heard the defamatory statements and failure to set forth the specific

words that Stolper allegedly stated that defamed Defendant.

“The elements of a cause of action for defamation are a false statement, published

without privilege or authorization to a third party, constituting fault as judged by, at a minimum,

a negligence standard, and it must either cause special harm or constitute defamation per se. The

complaint must set forth the particular words allegedly constituting defamation . . . and it must

also allege the time, place, and manner of the false statement and specify to whom it was made.”

Arvanitakis v. Lester, 145 A.D.3d 650, 651, 44 N.Y.S.3d 71, 72–73 (2d Dep’t 2016) (internal

quotations omitted).

Nor may a defamation cause of action simply paraphrase the alleged defamatory

statements but rather must recite them verbatim. See Manas v. VMS Assocs., LLC, 53 A.D.3d

451, 454–55, 863 N.Y.S.2d 4, 8 (2008) (“Regarding the cause of action for defamation, plaintiff

did not plead in the complaint the specific words allegedly used by McCausland–Seve, as

required by CPLR 3016(a), and has offered no excuse for her failure to do so. Instead, plaintiff

appears to have paraphrased the allegedly defamatory statements. Thus, ‘[s]ince the actual

defamatory words were never pleaded with particularity, but were only paraphrased in a manner

such that the actual words were not evident from the face of the complaint, the long-standing rule

is that dismissal is required’”); Stephan v. Cawley, 24 Misc. 3d 1204(A), 890 N.Y.S.2d 371 (Sup.

Ct. 2009) (“The three complaints addressed in this omnibus decision fail to state a cause of

action for defamation or slander per se. The complaints do not offer, in haec verba, particular

defamatory words claimed to have been published”) (defendants moved pursuant to CPLR

3211(a)(7) for failure to state a claim, and pursuant to CPLR 3016(a) for lack of the requisite

specificity in the claims for defamation.); AVGraphics, Inc. v. NYSE Grp., Inc., 22 Misc. 3d

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1139(A), 881 N.Y.S.2d 361 (Sup. Ct. 2009) (“the claimant must allege in the complaint the

particular words complained of and the time, place and manner in which the words were stated

must be set forth clearly and not paraphrased.”).

Here, Defendant’s counterclaim for defamation only paraphrases the alleged defamatory

words allegedly spoken by Stolper rather than setting them forth verbatim (“Plaintiff stated . . .

that Burbacki was not a really a licensed attorney” or “Plaintiff also told Ms. Bohorques that

Defendant had stolen millions of dollars from Plaintiff” or “Plaintiff had her assistant . . . send a

letter . . . stating that Defendant . . . had conspired with MC’s assistant . . . in order to extort

and/or humiliate MC”). (VAC ¶¶ 163, 164, 166). Accordingly, the counterclaim for defamation

must be dismissed. See Manas v. VMS Assocs., LLC, 53 A.D.3d at 454–55, 863 N.Y.S.2d at 8.

The counterclaim for defamation must also be dismissed to the extent that Defendant fails

to identify the specific individuals that allegedly heard the defamatory words and, instead,

merely states that a variety of non-specific individuals were exposed to the allegedly defamatory

words (“Plaintiff began defaming Defendant to various individuals” or “Ms. Bohorques observed

Plaintiff making these statements to a number of Defendant’s colleagues and to other

professionals in the entertainment industry and beyond.”). (VAC ¶¶ 162, 165). These

allegations are plainly deficient because they fail to identify the specific individuals that heard

the allegedly defamatory statements. Accordingly, these allegations fail to state a claim for

defamation. Rosenberg v. Home Box Office, Inc., 33 A.D.3d 550, 550, 822 N.Y.S.2d 921 (1st

Dep’t 2006) (“Plaintiff failed to plead the time, place and manner in which the alleged words

were stated, or any specifics as to third persons to whom the words were communicated.”);

Villacorta v. Saks Inc., 32 Misc. 3d 1203(A), 932 N.Y.S.2d 764 (Sup. Ct. N.Y. Cty 2011) (cause

of action for “libel/slander” was insufficiently pleaded where it “did not specifically

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name the persons to whom the alleged defamatory statements were made, as required by CPLR §

3016(a).”).

Finally, those allegations of defamation that pertain to MC, fail because Defendant never

identifies who MC is. Thus, it is impossible for Stolper to know to whom her alleged

defamatory statements pertain. Gill v. Pathmark Stores, Inc., 237 A.D.2d 563, 564, 655

N.Y.S.2d 623, 625 (2d Dep’t 1997) (“Failure to state the particular person or persons to whom

the allegedly defamatory comments were made also warrants dismissal”).

D. Tortious Interference Counterclaim is Duplicative

The counterclaim for tortious interference with business relations must be dismissed

because it is duplicative of the counterclaim for defamation and, since it is premised upon

alleged defamatory statements by Stolper, for all the reasons that the underlying defamation

counterclaim fails as set forth in Section C above.

A claim for tortious interference with advantageous business relations requires a party to

allege that: “(1) it had a business relationship with a third party; (2) the defendant knew of

that relationship and intentionally interfered with it; (3) the defendant acted solely out of malice,

or used dishonest, unfair, or improper means; and (4) the defendant's interference

caused injury to the relationship.” Men Women NY Model Mgmt., Inc. v. Ford Models, Inc., 32

Misc. 3d 1236(A), 938 N.Y.S.2d 228 (Sup. Ct. 2011) (dismissing cause of action where plaintiff

failed to allege a specific prospective economic relationship and where the complaint “suggests

that defendants engaged in the alleged acts out of a desire to benefit themselves, and did not act

solely out of malice nor to specifically injure the plaintiff”); see also G.K.A. Beverage Corp. v.

Honickman, 55 F.3d 762, 768 (2d Cir. 1995) (affirming dismissal of tortious interference with

prospective business relations claim).

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Defendants’ tortious interference counterclaim should be dismissed as duplicative of, and

based upon the same facts and damages as, the defamation counterclaim. Ripka v. City of

Madison, 80 N.Y.S.3d 479, 482 (3d Dep’t 2018) (affirming dismissal of claim where “Plaintiff’s

causes of action for tortious interference with business relations and prima facie tort cannot

survive, as they are based on the same substantive facts pleaded with respect to her defamation

cause of action and, thus, are duplicative of that claim”); see also Stern v. Burkle, 20 Misc. 3d

1101(A), 867 N.Y.S.2d 20 (Sup. Ct. 2008) (“Plaintiff’s tortious interference claim, which is

substantially duplicative of his defamation cause of action, is also dismissed.”); Goldman v.

Barrett, No. 15 CIV. 9223 (PGG), 2017 WL 4334011, at *4 (S.D.N.Y. July 25, 2017), aff'd, 733

F. App’x 568 (2d Cir. 2018) (dismissing tortious interference with prospective economic

advantage as duplicative of defamation claim); Lesesne v. Brimecome, 918 F. Supp. 2d 221,

224–25 (S.D.N.Y. 2013) (“As to the majority of the alleged malicious acts taken by [defendants],

the Court holds that claims arising from these acts sound in defamation rather than tortious

interference. Beginning with the allegedly false statements made on the internet . . . these appear

to be quintessential claims for defamation—the gravamen of these claims is that these false

statements injured the Plaintiffs by damaging [plaintiff’s] professional reputation. . . . There are a

plethora of cases in which courts have found that claims brought under the guise of other causes

of action actually sound in defamation, even if the plaintiff alleged economic harm.”).

Defendant’s tortious interference counterclaim also fails to establish the required

“causation” element. While the VAC is unclear as to exactly which of Stolper’s alleged acts

allegedly interfered with Defendant’s business relations with MC, Defendant appears to be

relying on the defamatory letter allegedly provided to MC’s head of security, Albert Mack.

(VAC ¶ 166). However, although Defendant alleges that “Plaintiff knew that Mack would then

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present the letter to MC” (VAC ¶ 168), she never alleges that Mack actually did present the letter

to MC. Additionally, Defendant does not plead that any of the other allegedly defamatory

statements Defendant attributes to Stolper were related to MC. Men Women NY Model Mgmt.,

Inc., 32 Misc. 3d 1236(A).

Furthermore, this counterclaim fails because Defendant never identifies MC. This makes

it impossible for Stolper to know which of Defendant’s business relations she allegedly

damaged. Deer Consumer Prod., Inc. v. Little Grp., 37 Misc. 3d 1224(A), 961 N.Y.S.2d 357

(Sup. Ct. N.Y. Cty 2012) (“Further, plaintiff failed to name a specific stockholder, investor or

financier with whom it had a relationship, with which [defendant] directly interfered, which is

fatal to its tortious interference with business relations claim.”)

Finally, as noted in the decision relating to Defendants’ motion to dismiss the complaint,

“[w]here tortious interference is based on a defamatory statement, pleading in accordance with

[the heightened pleading requirements of] CPLR 3016 is required.” (Decision and Order,

NYSCEF Doc. No. 26, at 2). Accordingly, Defendants’ tortious interference counterclaim fails

for the same reason that the defamation counterclaim fails as set forth in Section C hereof.

E. Defendant Fails to Plead the Elements of Unjust Enrichment/Quantum Meruit 4

The counterclaim for unjust enrichment/quantum meruit must be dismissed because it

fails to properly plead the type of work that Defendant allegedly performed for Stolper or that

Defendant had an expectation of compensation for such services.

In order to make out a claim in quantum meruit, a claimant must allege “(1) the

performance of services in good faith, (2) the acceptance of the services by the person to whom

4
Even though Defendant pleads them as a single cause of action, quantum meruit and unjust enrichment are two
separate causes of action. Regardless of whether Defendant’s intent is to plead one or the other or both, the
counterclaim fails and should be dismissed for the reasons set forth in Section E hereof.

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they are rendered, (3) an expectation of compensation therefor, and (4) the reasonable value of

the services.” Soumayah v. Minnelli, 41 A.D.3d 390, 391, 839 N.Y.S.2d 79, 81 (2007).

Defendant never properly identifies the work she allegedly performed on behalf of

Stolper. All the VAC alleges is that Defendant performed “personal work” for Stolper. What is

“personal work?” Stolper can only guess what is meant by this amorphous phrase. Defendant

must identify the actual services she allegedly performed. Her failure to do so is fatal to her

counterclaim. Cowles v. Minicucci, 1 A.D.3d 1060, 1060, 767 N.Y.S.2d 746 (4th Dep’t)

(affirming dismissal of quantum meruit claim where “[p]laintiff failed to establish either

the services decedent allegedly performed for defendant or the reasonable value of those alleged

services”); Singerman v. Reyes, 240 A.D.2d 335, 336, 659 N.Y.S.2d 762, 763 (1997)

(“Plaintiffs’ cause of action for quantum meruit is also without merit given their failure to

adequately document the services they allegedly performed for defendants or, assuming that

performance of such services could be documented, establish the reasonable value of those

services”); McCoy v. Admiral Metal Prod. Co., 160 N.Y.S.2d 961, 961 (App. Term 1st Dep’t

1957) (reversing denial of motion to dismiss where “[t]here has been no showing of the rendition

of services under circumstances which imply an agreement to pay therefor.”).

Defendant also fails to plead that she expected to be compensated for such services, and

this too is fatal to her counterclaim. Am.-European Art Assocs., Inc. v. Trend Galleries, Inc., 227

A.D.2d 170, 171, 641 N.Y.S.2d 835, 836 (1996) (affirming dismissal of quantum meruit claim

where “plaintiffs have failed to plead any reasonable expectation of being compensated for the

reasonable value of their services”); Fulbright & Jaworski, LLP v. Carucci, 63 A.D.3d 487, 489,

(1st Dep’t 2009) (“Notably, plaintiff offered no allegations that (1) [defendant] accepted services

from plaintiff, (2) plaintiff had a reasonable expectation of compensation from [defendant], or

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(3) the reasonable value of the services performed for which [defendant] was responsible. Nor

did plaintiff allege facts from which any of these elements reasonably can be inferred.”).

CONCLUSION

For the reasons set forth above, Stolper respectfully submits that her motion to dismiss

should be granted and all the counterclaims against her in the VAC be dismissed with prejudice.

Dated: March 25, 2019
New York, New York
Respectfully submitted,

KRUZHKOV RUSSO PLLC

By: /s/ Marlen Kruzhkov p
Marlen Kruzhkov, Esq.

350 Fifth Avenue, Suite 7230
New York, New York 10118
Tel.: (212) 363-2000
marlen@kruzhkovrusso.com

Attorneys for Plaintiff Stella Stolper

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Case Info

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Andrew Borrok Track Judge’s New Case

Case No.

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Document Filed Date

March 25, 2019

Case Filing Date

May 11, 2018

County

Parties

AYZEN, RIMMA Attorney for the Plaintiff
BRITAN, YANA VADIMOVNA Attorney for the Plaintiff
KRUZHKOV, MARLEN Attorney for the Plaintiff
NEUMAN, JONATHAN ELLERY Attorney for the Defendant
RUSSO, MARTIN PAUL Attorney for the Plaintiff
Stella Stolper Plaintiff
Zarina Burbacki Defendant
ELISEO NEUMAN Attorney
LESLIE MARTIN Attorney
RACINE RAMHURRY Attorney
ANDREA BROWN Attorney
WILTON WIDMAN Attorney
ANDREW BORROK Attorneys for Defendants
ERIC NEUMAN Attorneys for Defendants
SARAH KHURANA Attorney
DANIEL BRANOWER Attorneys for Plaintiffs
STEVEN BRATONE Attorney

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Motion-Secondary: Stella Stolper v. Zarina Burbacki

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