AFFIDAVIT OR AFFIRMATION IN REPLY (Motion #002) - Reply - Defendant Lambright - Edna Skinner v. Unified Marketing Llc, Pirs Capital, Llc, Daniel Ledven, Jacob Shimon, Alexander Parsol, Russell (Last Name Currently Unknown), Igor (Last Name Currently Unknown), James Lambright a/k/a JIM LAMBRIGHT in their individual capacities

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On December 16, 2016 a torts - other (employment discrimination) case was filed by Edna Skinner, represented by Akin, Zafer Adem, and Salaman, Robert Daniel, against Alexander Parsol, Daniel Ledven, Igor et al. represented by Chiu, Wing Keung, Lam, Nancy, Mestechkin, Oleg A., Zalkind, Eleanora, and Zelmati, Janice Adah Justine, in the jurisdiction of New York County. Judge Gerald Lebovits presiding.

                        
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                          FILED: NEW YORK COUNTY CLERK 10/09/2018 08:21 PM                                                 INDEX NO. 160582/2016
NYSCEF DOC. NO. 52                                                                       RECEIVED NYSCEF: 10/09/2018




          SUPREME COURT OF THE STATE OF NEW YORK
          COUNTY OF NEW YORK
          --------------------------------------------------------------X       Index No: 160582/2016
          EDNA SKINNER,

                                                      Plaintiff,

                                    -against-

          UNIFIED MARKETING LLC, PIRS CAPITAL,
          LLC and JIM LAMBRIGHT, in his individual
          capacity,

                                                       Defendants.
          --------------------------------------------------------------X

               AFFIRMATION OF SIMI BHUTANI IN REPLY AND FURTHER SUPPORT OF
               PLAINTIFF’S MOTION FOR LEAVE TO AMEND COMPLAINT AND AMEND
                             CAP…