On July 17, 2019 a
Motion-Secondary
was filed
involving a dispute between
Joy Freight, Inc.,
and
Heijung Park,
Jong Gul Park,
Mankyu Park,
Michael Park,
Mp Fashion,
New Mp Fashion,
for Torts - Other (Fraud, Nonpayment/Service)
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 01/24/2023 05:49 PM INDEX NO. 156993/2019
NYSCEF DOC. NO. 50 RECEIVED NYSCEF: 01/24/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
-----------------------------------------------------
X
:
JOY FREIGHT, INC., :
:
Plaintiff, : Index No.: 156993/2019
:
-against- : AFFIRMATION OF COUNSEL
:
NEW MP FASHION, MP FASHION, :
HEIJUNG PARK, MANKYU PARK, :
AND JONG GUL PARK, :
Defendants.
----------------------------------------------------X
ERIC S. MEDINA, an attorney duly admitted to practice law in the Courts of the State
of New York, hereby affirms, pursuant to CPLR §2106 under the penalties of perjury as follows:
1. I am a member of MEDINA LAW FIRM LLC, counsel for Defendant Jung Gul Park
(“Defendant”). I make this affirmation in regarding Defendant’s Order to Show Cause pursuant
for dismissal or in the alternative for vacatur of the judgment entered April 7, 2022 and seeking a
TRO (“Application”).
2. Per a directive from the NY County Clerk’s Office of January 23, 2023, I
transmitted the correspondence attached as Exhibit “A,” to Plaintiff Joy Freight, Inc. notifying
of the need to submit opposition to the interim relief sought by January 25, 2023, at 12:00 noon.
Dated: New York, New York
January 24, 2023
/s/ Eric S. Medina
Eric S. Medina, Esq.
641 Lexington Avenue
Thirteenth Floor
New York, NY 10022
Tel. (212) 404-1742
emedina@medinafirm.com
Attorneys for Defendant
{00089740} 1
1 of 2
FILED: NEW YORK COUNTY CLERK 01/24/2023 05:49 PM INDEX NO. 156993/2019
NYSCEF DOC. NO. 50 RECEIVED NYSCEF: 01/24/2023
EXHIBIT “A”
{00089740} 2
2 of 2
Document Filed Date
January 24, 2023
Case Filing Date
July 17, 2019
Category
Torts - Other (Fraud, Nonpayment/Service)
For full print and download access, please subscribe at https://www.trellis.law/.