successful legal representation of Ms. Svenson can be used to hold me or my paralegal liable topay Mr. Krichevsky's credit debts.8. Therefore, this Third-Party Action should be dismissed based upon CPLR
because neither my paralegal nor I can be
liable to Mr. Krichevsky for all or part of the
made by New Century Financial
Inc. based upon Mr. Krichevsky defaults inpayment of his credit card debt.
Krichevsky grossly overstates
That demand is well in excess of the monetary jurisdiction of thisCourt pursuant
to the New
Act § 202,
More importantly, Mr. Krichevsky unsuccessfully attempted to sue me on
very same grounds
the Supreme Court, Kings County, in an action entitled
v.Levoritz, Index No.
which was dismissed with prejudice.11. Mr. Krichevsky previously commenced
virtually the same
defendant, Elena Svenson in Supreme Court of the City of New York, County ofKings under Index No.
County Supreme Action )- The Complaint in that
A copy of the Court Order dismissing
action isannexed as
Exhibit C .
12. Thus, it has already been determined in the Kings County Supreme Action that
that Plaintiffs instantThird-Party Complaint is completely frivolous, Plaintiff is collaterally estopped from bringingvirtually the same lawsuit
Mr. Levoritz and Mr.
employee, Mr. Katkalov.
County Supreme Court Action
entered by the Court based upon my
sworn to December 21, 2010 ( Levoritz