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Motion to Disqualify Lorna J LaMotte Esq

Motion to Disqualify Lorna J LaMotte Esq

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Published by SLAVEFATHER
Motion to Disqualify Lorna LaMotte for violation of advocate-witness rule of NY RULES OF PROFESSIONAL CONDUCT
Motion to Disqualify Lorna LaMotte for violation of advocate-witness rule of NY RULES OF PROFESSIONAL CONDUCT

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Published by: SLAVEFATHER on Sep 24, 2013
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11/01/2013

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UNITED STATES BANKRUPTCY COURTRETURN DATE: , 2013EASTERN DISTRICT OF NEW YORK ---------------------------------------------------------xIN THE MATTER OF:ELENA SVENSON,CASE NO. 1-12-43050-essDebtor.CHAPTER 7--------------------------------------------------------xMICHAEL KRICHEVSKY,Plaintiff/Creditor,v.ELENA SVENSON,Adversary Proceeding No. 12-01229-essDefendant/debtor,BOARD OF MANAGERS OF OCEANACONDOMINIUM NO. TWO; INTERNALREVENUE SERVICE, INC.,Defendants/Creditors,VICTORIA EDELSTEIN, DDS; BORISKOTLYAR, COOPER SQUARE REALTY, INC;LANA KAPLUN, personally; FARIDBADALOV, personally; BORIS MEYDID, personally;JOHN DOE and JANE JOHNS, personally (fictitious names to be discovered),Defendants.------------------------------------------------------------------xVICTORIA EDELSTEIN, DDS and BORISKOTLYAR,Cross-Claimants,v.MICHAEL KRICHEVSKY,Cross-Defendant.-----------------------------------------------------------------x
NOTICE OF CROSS-MOTION TO DISQUALIFYC O U N S E L O R S :PLEASE TAKE NOTICE
, that upon the annexed supporting affidavit and memorandum of law, Michael Krichevsky moves for an order to Disqualify Lorna LaMotte, Esq., attorney for Elena Svenson (SVENSON), in this action on the following grounds:a)Ms. LaMotte additionally appeared in this action as an expert real state fact witnessfor SVENSON, thereby creating a conflict of interest in violation of advocate-witness
 
Rule 3.7 of NEW YORK RULES OF PROFESSIONAL CONDUCT (NYRPC) – LAWYER AS WITNESS; b)Ms. LaMotte additionally appeared in this action as unsworn fact witness for SVENSON, thereby creating a second conflict of interest in violation of Rule 3.7 of  NYRPC and in contempt of these rules;c)KRICHEVSKY will call Ms. LaMotte as witness during the trial;d)Ms. LaMotte violated Rule 3.1 of NYRPC – MERITORIOUS CLAIMS ANDCONTENTIONS;e)Ms. LaMotte violated Rule 3.3 of NYRPC – CONDOR FOR THE TRIBUNAL;f)Ms. LaMotte violated Rule 4.1 of NYRPC – TRUTHFULNESS IN STATEMENTSTO OTHERS;g)Ms. LaMotte substantially aiding and abetting commission of perjury by defendantSVENSON;h)Ms. LaMotte personally obstructing Justice and access to the court for KRICHEVSKY.The hearing will be held by Bankruptcy Judge Honorable Elizabeth S. Stong of this Court at theCourthouse located at 271 Cadman Plaza East, at Courtroom 3585, Brooklyn, NY 11201, onthe day of February, 2013, at 10 o'clock in the forenoon of that day, or as soon thereafter as counsel can be heard; and for such other and further relief as to this Court seems just and proper.
TAKE FURTHER NOTICE
that, pursuant to FRCP, all answering papers, if any, shall beserved at least seven (7) days before the return date of this motion.
 
Dated: Brooklyn, New York July 27, 2013______________________________ Michael Krichevsky, Pro Se4221 Atlantic AveBrooklyn, New York 11224(718) 687-2300tokrichevsky1@yahoo.com

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