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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 8 Filed 05/31/2007 Page 1 of 4
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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 8 Filed 05/31/2007 Page 2 of 4
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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 8 Filed 05/31/2007 Page 3 of 4
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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 

 

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