On December 16, 2016 a
Motion-Secondary
was filed
involving a dispute between
Edna Skinner,
and
Alexander Parsol,
Daniel Ledven,
Igor,
Jacob Shimon,
James Lambright A K A Jim Lambright In Their Individual Capacities,
James Lambright
A K A Jim Lambright In Their Individual Capacities,
Pirs Capital, Llc,
Russell,
Unified Marketing Llc,
for Torts - Other (Employment Discrimination)
in the District Court of New York County.
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FILED: NEW YORK COUNTY CLERK 01/23/2019 09:09 PM INDEX NO. 160582/2016
NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 01/23/2019
SUPREME COURT OF STATE OF NEW YORK
COUNTY OF NEW YORK
EDNA SKINNER,
Plaintiff,
Index No. 160582/16
-against-
Motion Sequence # 003
UNIFIED MARKETING, LLC, PIRS CAPITAL,
LLC, ALEXANDER PARSOL, RUSSELL (last AFFIRMATION IN OPPOSITION
name currently unknown), IGOR (last name TO PLAINTIFF’S SECOND
currently unknown), and JAMES LAMBRIGHT MOTION TO AMEND SUMMONS
a/k/a JIM LAMBRIGHT, in their individual AND VERIFIED COMPLAINT
capacities,
Defendants.
OLEG A. MESTECHKIN, an attorney duly admitted to practice before the courts of the
State of New York, hereby affirms under the penalty of perjury, pursuant to CPLR § 2106:
1. I am a member of the Mestechkin Law Group, P.C, attorneys for defendants
Unified Marketing, LLC (“Unified”) and PIRS Capital, LLC (“PIRS”), (collectively, “Corporate
Defendants”) and as such, I am familiar with the facts and circumstances surrounding this action.
2. I submit this affirmation, together with the accompanying Memorandum of Law,
in opposition to Plaintiff’s motion pursuant to CPLR 3025(b) seeking leave to amend her First
Amended Summons and Verified Complaint.
3. A true and correct copy of excerpts from the transcript of the May 17, 2018
Deposition of Edna Skinner is attached hereto as Exhibit 1.
4. A true and correct copy of the print out from Plaintiff’s LinkedIn webpage is
attached hereto as Exhibit 2.
1
1 of 2
FILED: NEW YORK COUNTY CLERK 01/23/2019 09:09 PM INDEX NO. 160582/2016
NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 01/23/2019
Dated: Brooklyn, New York Respectfully submitted,
January 23, 2019
/s/ Oleg A. Mestechkin .
Oleg A. Mestechkin, Esq.
Wing K. Chiu, Esq.
Nancy Lam, Esq.
MESTECHKIN LAW GROUP P.C.
1733 Sheepshead Bay Road, Suite 29
Brooklyn, New York 11235
Tel. (212) 256-1113
Fax. (646) 358-4906
om@lawmlg.com
wkc@lawmlg.com
nl@lawmlg.com
Attorneys for Defendants Unified
Marketing, LLC and PIRS Capital, LLC
2
2 of 2
Document Filed Date
January 23, 2019
Case Filing Date
December 16, 2016
Category
Torts - Other (Employment Discrimination)
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FILED: NEW YORK COUNTY CLERK 01/23/2019 09:09 PM INDEX NO. 160582/2016 NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 01/23/2019 SUPREME COURT OF STATE OF NEW YORK COUNTY OF NEW YORK EDNA SKINNER, Plaintiff, Index No. 160582/16 -against- Motion Sequence # 003 UNIFIED MARKETING, LLC, PIRS CAPITAL, LLC, ALEXANDER PARSOL, RUSSELL (last AFFIRMATION IN OPPOSITION name currently unknown), IGOR (last name TO PLAINTIFF’S SECOND currently unknown), and JAMES LAMBRIGHT MOTION TO AMEND SUMMONS a/k/a JIM LAMBRIGHT, in their individual AND VERIFIED COMPLAINT capacities, Defendants. OLEG A. MESTECHKIN, an attorney duly admitted to practice before the courts of the State of New York, hereby affirms under the penalty of perjury, pursuant to CPLR § 2106: 1. I am a member of the Mestechkin Law Group, P.C, attorneys for defendants Unified Marketing, LLC (“Unified”) and PIRS Capital, LLC (“PIRS”), (collectively, “Corporate Defendants”) and as such, I am familiar with the facts and circumstances surrounding this action. 2. I submit this affirmation, together with the accompanying Memorandum of Law, in opposition to Plaintiff’s motion pursuant to CPLR 3025(b) seeking leave to amend her First Amended Summons and Verified Complaint. 3. A true and correct copy of excerpts from the transcript of the May 17, 2018 Deposition of Edna Skinner is attached hereto as Exhibit 1. 4. A true and correct copy of the print out from Plaintiff’s LinkedIn webpage is attached hereto as Exhibit 2. 1 1 of 2 FILED: NEW YORK COUNTY CLERK 01/23/2019 09:09 PM INDEX NO. 160582/2016 NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 01/23/2019 Dated: Brooklyn, New York Respectfully submitted, January 23, 2019 /s/ Oleg A. Mestechkin . Oleg A. Mestechkin, Esq. Wing K. Chiu, Esq. Nancy Lam, Esq. MESTECHKIN LAW GROUP P.C. 1733 Sheepshead Bay Road, Suite 29 Brooklyn, New York 11235 Tel. (212) 256-1113 Fax. (646) 358-4906 om@lawmlg.com wkc@lawmlg.com nl@lawmlg.com Attorneys for Defendants Unified Marketing, LLC and PIRS Capital, LLC 2 2 of 2