Gucci America, Inc. v. Frontline Processing Corporation et al

Filing 81

DECLARATION of Todd Wengrovsky in Opposition re: 66 MOTION for Summary Judgment.. Document filed by Durango Merchant Services LLC. (Attachments: # 1 Exhibit B, # 2 Exhibit C)(Wengrovsky, Todd)

Gucci America, Inc. v. Frontline Processing Corporation et al

Doc. 81

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK ------------------------------------------------------------------X GUCCI AMERICA, INC., Plaintiff, DECLARATION OF TODD WENGROVSKY IN SUPPORT OF DURANGO'S OPPOSITION TO PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT Civil Index No. 09-6925

-againstFRONTLINE PROCESSING CORPORATION, WOODFOREST NATIONAL BANK, DURANGO MERCHANT SERVICES LLC d/b/a NATIONAL BANKCARD SYSTEMS OF DURANGO, Defendants. ------------------------------------------------------------------X

Todd Wengrovsky, an attorney duly admitted to practice in the United States District Court for the Southern District of New York, under the penalty of perjury, states: 1. I am the attorney for Defendant Durango Merchant Services, LLC. in the present action and offer this Declaration in support of Durango's Opposition to Plaintiff's Motion for Summary Judgment. 2. Attached hereto as EXH. A is a true and correct copy of a standard processing agreement between a merchant and a credit card processing bank. 3. Attached hereto as EXH. B is a true and correct copy of a March, 2006 article entitled "Security Breach Notification Requirements: Guidelines and Securities Law Considerations." 4. Attached hereto as EXH. C is a true and correct copy of Durango's Answers to Gucci's Interrogatories, dated January 29, 2010.

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Dated: August 1, 2010 Calverton, New York /s/ Todd Wengrovsky Todd Wengrovsky - TW4823 Law Offices of Todd Wengrovsky, PLLC. 285 Southfield Road, Box 585 Calverton, NY 11933 Tel [phone] Fax [phone] Attorney for Defendant Durango Merchant Services, LLC.

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