Mikhlyn et al v. Bove et al

Filing 214

AFFIDAVIT/DECLARATION in Opposition re 189 REPORT AND RECOMMENDATIONS re 130 First MOTION for Sanctions Pursuant to Rule 37 and for Default Judgment Pursuant to Rule 55 filed by Inga Mikhlyn, ABC All Consulting, Inc., Vadim MikhlynREPORT AND RECOMMENDATIONS re 130 First MOTION for Sanctions Pursuant to Rule 37 and for Default Judgment Pursuant to Rule 55 filed by Inga Mikhlyn, ABC All Consulting, Inc., Vadim MikhlynREPORT AND RECOMMENDATIONS re 130 First MOTION for Sanctions Pursuant to Rule 37 and for Default Judgment Pursuant to Rule 55 filed by Inga Mikhlyn, ABC All Consulting, Inc., Vadim MikhlynREPORT AND RECOMMENDATIONS re 130 First MOTION for Sanctions Pursuant to Rule 37 and for Default Judgment Pursuant to Rule 55 filed by Inga Mikhlyn, ABC All Consulting, Inc., Vadim Mikhlyn, 210 First MOTION for Leave to Electronically File Document under Seal in Response to Opposition by Boris Kogan and Associates (Doc. No. 201)First MOTION for Leave to Electronically File Document under Seal in Response to Opposition by Boris Kogan and Associates (Doc. No. 201)First MOTION for Leave to Electronically File Document under Seal in Response to Opposition by Boris Kogan and Associates (Doc. No. 201), 201 Letter MOTION for Leave to Electronically File Document under Seal, RULE 56.1 STATEMENT re 189 REPORT AND RECOMMENDATIONS re 130 First MOTION for Sanctions Pursuant to Rule 37 and for Default Judgment Pursuant to Rule 55 filed by Inga Mikhlyn, ABC All Consulting, Inc., Vadim MikhlynREPORT AND RECOMMENDATIONS re 130 First MOTION for Sanctions Pursuant to Rule 37 and for Default Judgment Pursuant to Rule 55 filed by Inga Mikhlyn, ABC All Consulting, Inc., Vadim MikhlynREPORT AND RECOMMENDATIONS re 130 First MOTION for Sanctions Pursuant to Rule 37 and for Default Judgment Pursuant to Rule 55 filed by Inga Mikhlyn, ABC All Consulting, Inc., Vadim MikhlynREPORT AND RECOMMENDATIONS re 130 First MOTION for Sanctions Pursuant to Rule 37 and for Default Judgment Pursuant to Rule 55 filed by Inga Mikhlyn, ABC All Consulting, Inc., Vadim Mikhlyn filed by Boris Kogan. (Attachments: # 1 Exhibit 1-27-10 Email, # 2 Exhibit 5-7-10 Email, # 3 Exhibit 5-13-09 Letter, # 4 Exhibit 6-26-09 Letter Motion, # 5 Exhibit 8-14-09 Letter, # 6 Exhibit 11-2-09 Excerpt from Transcript, # 7 Exhibit List of Outstanding Discovery Owed by Plaintiffs, # 8 Exhibit BK&A Retainer Agreement, # 9 Exhibit 5-3-09 Letter, # 10 Exhibit 5-17-10 Email) (Kogan, Boris)

Mikhlyn et al v. Bove et al

Doc. 214

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK --------------------------------------------------------------x : SEAN STEPHEN and DARYL STEPHEN : : Plaintiffs, : : -against: : POLICE OFFICER JOHN HANLEY, Shield No. : 13199, POLICE OFFICER EDGAR BOURDON, : Shield No. 30988, SERGEANT JUAN WHITE, : POLICE OFFICER MICHAEL ILIADIS, : POLICE OFFICER TERRANCE BRILL, : POLICE OFFICER STEVE HAYDEN, : POLICE OFFICE PATRICK COLEMAN, : POLICE OFFICE DEREK DUNSTON, : POLICE OFFICE RICHARD MILLER, and : DETECTIVE JOSE HERNANDEZ, : : Defendants. : --------------------------------------------------------------x

DECLARATION OF DAVID MCGILL 03-CV-6226 (KAM)

David McGill, declares under penalty of perjury and pursuant to 28 U.S.C. § 1746 that the following statements are true and correct: 1. I am an attorney from Mayer Brown, LLP, representing Plaintiffs Sean and Daryl Stephen. As such, I am familiar with the facts stated below and, as well, submit this declaration to place relevant documents on the record for Plaintiffs' Motion In Limine to Exclude Evidence at Trial as Inadmissible Hearsay. 2. Attached as Exhibit "1" are transcript excerpts of the March 31, 2008 deposition of Chestimah O'Neil. Plaintiffs' behalf. Ms. O'Neil is a non-party witness who will be testifying on

Dockets.Justia.com

Dated: February 20, 2009 Respectfully submitted, MAYER BROWN LLP By: /S/ David H. McGill David McGill 1675 Broadway New York, NY 10019 Tel: [phone] Fax: [phone] Email: [e-mail] Attorneys for Plaintiffs

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