AFFIDAVIT OR AFFIRMATION IN SUPPORT OF MOTION (Motion #001) - Clark Aff in Support of Motion to Dismiss - xxxxxxxx xxxx, All Other Persons Similarly Situated v. Hornblower New York, Llc, Hornblower Yachts, Inc., Terry Macrae, Hornblower Cruises & Events

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On November 5, 2014 a contract (non-commercial) case was filed by All Other Persons Similarly Situated, and Xxxxxxxx Xxxx, represented by Ambinder, Lloyd R, Ambinder, Lloyd Robert, Brown, Jeffrey Kevin et al. against Hornblower Cruises & Events, Hornblower New York, Llc, Hornblower Yachts, Inc., and Terry Macrae, represented by Ruocco, Jaclyn Kate, Stoll, Judith A., and Traub, Lois Marcus, in the jurisdiction of New York County. Judge Carol Edmead presiding.

                        
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INDEX   NO.    160993/2014
(FILED: NEW YORK COUNTY CLERK 0272772015 11:35 AM
NYSCEF   DOC.   NO.   9                                          RECEIVED   NYSCEF:   02/27/2015




                          CLARK AFFIDAVIT TO NOTICE OF MOTION TO DISMISS

                                        INDEX NO. 160993/2014
STATE OF NEW YORK             )
COUNTY OF NEW YORK             )

      CAMERON CLARK, being duly sworn, deposes and says:

      {am the Vice President and General Manager of Hornblower New York, LLC d/b/a

      Hornblower Cruises and Events (hereinafter “Hornblower Cruises”).       [ submit this

      Affidavit in support of Defendants’ Motion to Dismiss.

      Since in or about April 2012, Hornblower Cruises has operated event and dining cruises

      in and around the various waterways surrounding New York City, including the Hudson

      River East Rivers and New York Harbor.      Terry MacRae is the President and Chief

      Executive Officer of Hornblower Cruises…