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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF NEW YORK 

LISA-ATHENA S. ABU HANTASH, in her 

individual capacity and as mother and natural 

guardian of JORDAN-ANNETTEE JAZZMIN 

RICHARDSON, a minor, and JORDAN 

RICHARDSON, INC., a Virginia Corporation, 

 Plaintiffs, 

 

-against- 

 

V MODEL MANAGEMENT NEW YORK, INC. 

and VNY MODEL MANAGEMENT, LLC, 

 Defendants. 

 Docket No.: 07 Civ. 3363 (GBD) (KNF) 

NOTICE OF MOTION FOR 

SUMMARY JUDGMENT OR, IN 

THE ALTERNATIVE, AN ORDER 

DIRECTING A SPEEDY HEARING 

AND ADVANCING THE ACTION 

ON THE TRIAL CALENDAR 

PURSUANT TO FED. R. CIV. P. 57 

(ORAL ARGUMENT REQUESTED) 

PLEASE TAKE NOTICE that upon the Statement of Undisputed Facts, the affirmation 

of Gavin I. Handwerker, Esq. with exhibits, the affidavit of Plaintiff Lisa-Athena Abu Hantash 

dated May 24, 2007 with exhibits, the affidavit of Jordan-Annettee Jazzmin Richardson dated 

May 24, 2007 with exhibits and the Memorandum of Law submitted in support of Plaintiff’s 

motion, the Plaintiffs, Lisa-Athena S. Abu Hantash (“Abu Hantash”), in her individual capacity 

and in her capacity as mother and natural guardian of Jordan-Annettee Jazzmin Richardson 

(“Jordan Richardson”), a minor, and Jordan Richardson, Inc. (the “Company”), by and through 

their attorneys, NISSENBAUM LAW GROUP, LLC, will move this Court before the Honorable 

George B. Daniels, United States District Court Judge, at the United States Courthouse for the 

Southern District of New York, located at 500 Pearl Street, New York, New York, Courtroom 

15D, on Friday, June 22, 2007 at 9:30a.m., or at such other date and time as the Court may 

direct, where counsel may be heard for the entry of an Order: 

Case 1:07-cv-03363-GBD Document 12 Filed 06/01/2007 Page 1 of 5
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1. Pursuant to Fed. R. Civ. P. 56, granting summary judgment in favor of Plaintiffs 

and against Defendants on all causes of action; 

2. Pursuant to the Federal Declaratory Act, 28 U.S.C.A. § 2201 et seq., declaring the 

agreement dated April 22, 2005 between Jordan Richardson and Defendant V Model 

Management New York, Inc. null and void; 

3. In the alternative, rescinding the agreement dated April 22, 2005 between Jordan 

Richardson and Defendant V Model Management New York, Inc. on the grounds that the 

agreement is unconscionable; 

4. Pursuant to the Federal Declaratory Act, 28 U.S.C.A. § 2201 et seq., declaring 

that the agreement dated June 19, 2006 between Defendant VNY Model Management, LLC and 

Plaintiff Company is not a legally binding contract; 

5. In the alternative and pursuant to the Federal Declaratory Act, 28 U.S.C.A. § 2201 

et seq., declaring the agreement dated June 19, 2006 between Plaintiff Company and Defendant 

VNY Model Management, LLC is null and void; 

6. Granting permanent injunctive relief restraining and enjoining Defendants, their 

employees, agents, servants and all persons acting under their direction, control or in concert 

with them from: 

(a) asserting that any of the aforementioned agreements are enforceable; and, 

(b) interfering with Plaintiffs’ contract relations with any person, firm, 

company, corporation and/or other entity with regards to Jordan Richardson’s modeling career. 

Case 1:07-cv-03363-GBD Document 12 Filed 06/01/2007 Page 2 of 5
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7. Requiring each of the Defendants to file with this Court and serve on Plaintiffs 

within ten (10) days after service of the permanent injunction, a report, in writing, under oath, 

setting forth in detail the manner and form in which the Defendants have complied with the 

permanent injunction; 

8. Directing Defendants to account to Plaintiffs for all monies received from third 

persons with regard to Jordan’s modeling services and the amount, description and 

documentation for all of the deductions made by Defendants; 

9. In the event the Court denies Plaintiffs’ request for summary judgment, in part or 

in its entirety, ordering a speedy hearing and advancing the above-captioned matter on the trial 

calendar pursuant to Fed. R. Civ. P. 57; 

10. Awarding attorney’s fees, costs and disbursements; and 

11. Granting such other, further and different relief as to this Court seems just, 

equitable and proper under the circumstances. 

Case 1:07-cv-03363-GBD Document 12 Filed 06/01/2007 Page 3 of 5
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PLEASE TAKE FURTHER NOTICE that in accordance with Local Rule 6.1(b), 

answering papers, if any, are to be served within ten (10) business days after service of these 

moving papers. 

Dated: New York, New York 

 May 31, 2007 

 Yours, etc., 

 NISSENBAUM LAW GROUP, LLC 

 /S/ GAVIN I. HANDWERKER 

 By: Gavin I. Handwerker (GIH6191) 

 Attorneys for Plaintiffs

 140 Broadway, 46th Fl. 

 New York, New York 10005 

 (212) 871-5711 

To: Wilmer H. Grier, Esq. 

Attorneys for Defendants 

V MODEL MANAGEMENT NEW YORK, INC. and 

VNY MODEL MANAGEMENT, LLC 

603 Jefferson Avenue 

Brooklyn, New York 11221 

 

Case 1:07-cv-03363-GBD Document 12 Filed 06/01/2007 Page 4 of 5
AFFIRMATION OF SERVICE

GAVIN I. HANDWERKER, an attorney duly admitted to practice law in the Courts of 

the State of New York affirms the following to be true under the penalties of perjury: 

 That on June 1, 2007, I served the within NOTICE OF MOTION, STATEMENT 

PURSUANT TO RULE 56, MEMORANDUM OF LAW, ATTORNEY AFFIRMATION WITH 

EXHIBITS, AFFIDAVIT OF LISA HANTASH WITH EXHIBITS, and AFFIDAVIT OF 

JORDAN RICHARDSON WITH EXHIBITS, in the following manner: 

 By depositing a true copy thereof enclosed in a post-paid wrapper, in an official 

depository under the exclusive care and control of the United States Postal Service 

addressed to each of the persons listed below at the last known address set forth after 

each name; 

 By delivering a true copy thereof personally to each person listed below at the address 

indicated. I knew each person served to be the person mentioned and described in said 

papers as a party therein, or their attorney authorized to accept service; 

 By transmitting the papers by electronic means to the telephone/FAX number listed 

below, which number was designated by the attorney/ party for such purpose. I received 

a signal from the equipment of the attorney/party served indicating that the transmission 

was received. I also deposited a true copy of the papers, enclosed in a post-paid wrapper, 

in an official depository under the exclusive care and custody of the U.S. Postal Service, 

addressed to the attorney/party at the address listed below; 

 X By depositing a true copy thereof, enclosed in a wrapper addressed as shown below, into 

the custody of A FEDERAL EXPRESS COURIER for overnight delivery, prior to the 

latest time designated by that service for overnight delivery; 

 By delivering a true copy thereof by electronic means to the email address listed below, 

which said electronic mail address was designated by the attorney/party for such purpose. 

NAMES/ADDRESSES/FAXES OF PARTIES SERVED

Wilmer H. Grier, Esq. 

Attorneys for Defendants

V MODEL MANAGEMENT NEW YORK, INC. and 

VNY MODEL MANAGEMENT, LLC 

603 Jefferson Avenue 

Brooklyn, New York 11221 

Dated: New York, New York 

 June 1, 2007 

 /S/ GAVIN I. HANDWERKER 

 GAVIN I. HANDWERKER (GIH6191) 

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