Mikhlyn et al v. Bove et al

Filing 131

MEMORANDUM in Support re 130 First MOTION for Sanctions Pursuant to Rule 37 and for Default Judgment Pursuant to Rule 55 filed by ABC All Consulting, Inc., Inga Mikhlyn, Vadim Mikhlyn. (Mandel, Val)

Mikhlyn et al v. Bove et al

Doc. 131

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK ----------------------------------------------------------------x Orville Bolin, Ezekielisha Anselme and Roland Camacho, Plaintiffs, v. Harvard Protection Services, Inc., Harvard Protection Services, LLC, Quality Protection Services, Inc., Quality Building Services, Inc. and Mirjana Mirjanic, Defendants. ----------------------------------------------------------------x As and for his Declaration, Wylie M. Stecklow, Esq. declares: 1. Annexed hereto as Exhibit A is a true and accurate copy of an order signed by the DECLARATION OF WYLIE M. STECKLOW (WMS 6012)

99 CV 8187 (JG) (VVP)

Honorable Magistrate Judge Viktor V. Pohorelsky in this matter dated June 5, 2003. 2. Annexed hereto as Exhibit B is a true and accurate computer generated copy of a letter

submitted to the Honorable Magistrate Judge Viktor V. Pohorelsky from myself dated December 2, 2003. 3. Annexed hereto as Exhibit C is, (i) a copy of a correspondence dated May 18, 2006 from

counsel for Harvard Defendants to all counsel in this matter but addressed to Mr. Camacho's counsel at an address that has been invalid since September 2001 (225 Broadway); and (ii) a correspondence from Harvard Defendants Counsel to the Honorable Judge Gleeson dated July 22, 2005 indicating that a fax they sent to the Court was never received by the Court. 4. Annexed hereto as Exhibit D a true and accurate copy of an e-mail forwarded to all

counsel in this litigation on June 9, 2006 at approximately 3:39 pm.

Dockets.Justia.com

June 19, 2006 New York, N.Y.

Respectfully submitted,

____________________________ WYLIE M. STECKLOW (WMS 6012) Attorney for Plaintiff Roland Camacho 10 Spring N Y C 10012 [phone] www.wylielaw.com