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27
Case 1:05-cv-09137-DLC Document 27 Filed 02/10/2006 Page 1 of 5
DAVID NORKIN,
-against-
Defendant.
----------------------------------X
York;
Dockets.Justia.com
Case 1:05-cv-09137-DLC Document 27 Filed 02/10/2006 Page 2 of 5
transferred.
Defendant does not explain how this can be, in view of the fact
the facts has supported this claim with an affidavit. One witness,
2
Case 1:05-cv-09137-DLC Document 27 Filed 02/10/2006 Page 3 of 5
motions have been fully briefed and are sub judice. By contrast,
discovery in the case has not commenced, and defendant has not even
or factual issues which are common to the two cases which would
the case.
3
Case 1:05-cv-09137-DLC Document 27 Filed 02/10/2006 Page 4 of 5
claim that Piper gave him bad advice as well. Nor does
but with Norkin” (id.) conflict with Mr. Norkin’s claim –- which
the two claims are remarkably consistent. The fact that Piper also
case for transfer. In Britestarr, the company had moved its office
4
Case 1:05-cv-09137-DLC Document 27 Filed 02/10/2006 Page 5 of 5
A, p. 1)
Conclusion
Respectfully submitted,
By:______________________________
Richard M. Asche (RMA-7081)