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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF KINGS
`--------------------------------------------------------------------x
`EVA VIOLANTE,
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`Plaintiff,
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`-against-
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`ANGIE WONG a/k/a ANGIE WONG SIE YING,
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`Defendant.
`--------------------------------------------------------------------x
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`PRELIMINARY STATEMENT
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`Motion Seq. 001
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`PLAINTIFF’S REPLY
`MEMORANDUM OF
`LAW IN OPPOSITION
`TO DEFENDANT AND
`IN SUPPORT OF
`SUMMARY JUDGMENT
`TO PLAINTIFF
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`Index No. 517535/2020
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`This Reply Memorandum of Law is respectfully submitted in response to the
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`Supplemental Memorandum of Law filed by defendant Angie Wong on December 20, 2021.
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`Plaintiff requests that this Court grant her Summary Judgment on the three causes of action set
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`forth in the Complaint, (1) Recovery of Chattel, (2) Conversion and (3) Intentional Infliction of
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`Emotional Distress. pursuant to CPLR Rule 3212(b).
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`ANGIE WONG’S JOINDER OF ISSUE
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`Defendant Angie Wong has finally disclosed her defense to this action: a not very
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`creative and internally inconsistent work of fiction. The knee-jerk excuse of someone caught
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`“red-handed” with the property of another is to claim that the owner gave it to them as a
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`gift, and that is the tale Angie Wong is telling in her Supplemental Affidavit of Angie Wong,
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`sworn to December 20, 2021 (the “2nd Angie Affidavit”) and her nearly identical Rule 202.8-g
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`Statement of Material Facts of even date.1
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`1 Plaintiff did not wish to be compelled to respond to the material and trivial facts in
`defendant’s inappropriately prolix Statement of Material Facts, which was a nearly word-for-
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`Angie Wong’s Story
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`Angie Wong has provided no evidence to support her story, beyond her own very
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`melodramatic testimony that in a telephone call on August 6, 2020, plaintiff Eva Violante had
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`“begged” Wong, a veritable stranger, to permanently take plaintiff’s dog, Louie, whom plaintiff
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`had purchased for $3,500 only ten days earlier, ostensibly because plaintiff’s boss forbade Eva
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`from ever bringing the dog to the office. Wong avers that plaintiff, who had met Wong briefly,
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`only once, on July 25, 2020, at the pet shop, told Wong that plaintiff’s dog and Wong’s family
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`“would be a good fit, given how much [Wong’s] children liked him at Citipups.” (2nd Angie
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`Affidavit ¶13).
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`Early Texts with Angie Wong and Alicia
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`On July 27, 2020, the day that both Wong and plaintiff, separately, picked up
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`their respective dogs at Citipups, Wong initiated (3-way) texts with plaintiff and Alicia Inman
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`(“Alicia”) the owner of another sibling from the litter. (See, Exhibit “B” Violante Affidavit of
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`1/6/2022, hereinafter “Exhibit ‘B’/2022”). The three women texted again on August 4, 2020,
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`with each of them sharing photos of their dogs, including 2 photos sent by plaintiff, of Louie
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`sleeping on plaintiff’s desk in her office and sitting near a friend’s pool. During the August 4th
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`texts, the play-date was arranged, ostensibly at the instance of Wong’s young daughter “Maddy”,
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`word reiteration of the Second Angie Affidavit, in a Response and then, like defendant, repeat it
`all over again in affidavit form simply to provide evidentiary support for the Response.
`Accordingly, plaintiff has verified her Response and written her own shorter affidavit, both to
`relieve the Court of wasteful duplication of effort and to allow plaintiff to have agency and
`control over the issues she wanted to address.
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`using her mother’s phone. Id. There are additional texts on Friday August 7, both before and after
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`the play-date and a few final texts on August 10th. Id.
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`August 6th, the day Angie Wong claims that plaintiff “begged” her to take her dog,
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`was 2 days after the August 4th texts and one day before the play-date. As of August 6th, plaintiff
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`knew little more about Wong than that she had never before owned a dog. (Violante Affidavit
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`sworn to 1/6/2022, ¶7; Exhibit “B”/2022).
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`The Play-Date on August 7, 2020
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`The play-date on Friday night, August 7th, was very pleasant and Angie Wong
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`seemed to be a good host. (Violante Affidavit sworn to 1/6/2022, ¶9). The women drank wine
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`and ate cheese. (Violante Affidavit sworn to 12/20/2021, ¶4). Plaintiff mentioned some
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`important in-person client meetings she had the following week to which she would be unable to
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`bring Louie. Angie Wong was extremely eager to accommodate plaintiff’s situation and offered
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`to take care of Louie for a few days, saving plaintiff a trip upstate to her parents’ house. (Violante
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`Affidavit sworn to 1/6/2022, ¶9; Violante Affidavit sworn to 12/20/2021, ¶6 ).
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`Monday, August 10, 2020
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`Having taken Angie Wong up on her kind offer to dog-sit Louie for a few days
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`that week, plaintiff brought him to Wong’s apartment in the evening of August 10, 2020. On the
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`way over, plaintiff went to Pet Smart and bought some “pee pee pads” and dog treats to leave
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`with Wong during the dog-sitting. Violante Affidavit sworn to 1/6/2022, ¶16 and Exhibit “D”).
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`According to Wong, plaintiff dropped Louie off at Wong’s apartment on that
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`Monday evening permanently, having called Wong on the telephone earlier that day, in response
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`to Wong’s text from the prior Saturday, August 8th in which Wong stated, in pertinent part: “I
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`hope you can find a way to keep him. If you can’t, we are happy to provide him a home. It was
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`great to see you both and thank you for the wine.” (2nd Angie Affidavit Exhibit “3”, Doc #40 and
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`Violante Affidavit 12/20/2021, Exhibit “B” (hereinafter “Eva’s Exhibit “B”, Doc #50”).2
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`Plaintiff had seen that August 8th text from Wong on Saturday morning, but she
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`ignored it; she didn’t even respond, chalking it up to Wong being overly generous; offering too
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`much. (Violante Affidavit sworn to 1/6/2022, ¶16). After dropping Louie off that Monday
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`evening, Wong and plaintiff texted each other about how the evening was going. Wong reported:
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`“They have calm down and are sharing dinner now. I’ll try you tomorrow.” to which plaintiff
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`responded “Ok good! Good luck and have a great night!!! Later, Wong wrote: “They’ve tired
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`each other out. I’ll move him to a bed soon.” The manner in which Wong reported all details of
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`the evening to plaintiff confirms that Wong was simply dog-sitting Violante’s dog.
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`Tuesday, August 11, 2020
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`On Tuesday morning, August 11th, at 9:36 am Angie Wong texted plaintiff to
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`report: “The two kids had a disco party last night, but then fell right back to sleep. Not too much
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`2 Both Wong and plaintiff have annexed the string of texts between them as exhibits, but
`Wong ends her’s the morning after she flew down to Miami (August 14th). Plaintiff kept texting
`Wong through August 21, 2020, trying to get Wong to respond to her and plaintiff’s exhibit
`includes all of those texts. Accordingly plaintiff will cite to her own Exhibit “B” to her Affidavit
`of 12/20/2021 (“Eva’s Exhibit “B”, Doc #50).
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`drama for the first night. Whew.” At 8:29 that evening, plaintiff texted “Hi Angie, hope all is
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`going well. I’m going to get out early tomorrow. Would you mind if I come by and see how
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`Louie is doing? I would probably be able to be there at 1:30 or so. I have some tick medicine for
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`him as well. If evening is better for you I can do that too.” Clearly, plaintiff was coming to
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`check on her dog and put medicine on him. She asked “[w]ould you mind?” merely to be polite
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`and not inconvenience Wong’s schedule. (“Eva’s Exhibit “B”, Doc #50)
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`Wednesday, August 12, 2020
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`On Wednesday, August 12th, plaintiff stopped by Wong’s apartment and put the
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`medicine on her dog. But Wong’s demeanor was very different than previously. She was cold,
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`brusque and rushed plaintiff out as if she didn’t want her there. Looking back, plaintiff is now
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`certain that Wong must have been hurriedly packing her bags to make her escape to Florida.
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`(Violante Affidavit 12/20/2021 ¶7; Violante Affidavit 1/6/2022 ¶18).
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`Thursday, August 13, 2020
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`By reason of Wong’s sudden change of personality, plaintiff began to think that
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`something was amiss. She realized that Wong had her dog and might have no intention of
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`returning him. She sent Wong a text about picking up Louie that day to bring him to her mother
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`upstate. She sent a second text offering to transfer ownership of Louie to Wong, including all
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`documentation, IF her mother could not look after Louie. Plaintiff was hoping to get Wong to
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`give Louie back to her voluntarily. Angie Wong’s response was to ask to keep Louie and she
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`offered to pay for him:
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`Hi Eva, would it be ok for us to keep
`Louie? My kids have really taken to
`him and the two pups are kind of
`inseparable now. We also just
`bought airline tickets for the two.
`I’m happy to cover your costs from
`Citipups, sorry I didn’t offer sooner.
`My offer still stands if you want
`have Louie or both dogs when you
`have vacation days etc.
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`Plaintiff texted “I’m thinking about your offer, and I’ll get back to you.” in order
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`to buy time. She assumed that Wong had bought airline tickets for Miami, and texted Wong
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`asking when Wong was taking Louie to Miami? But Wong never communicated with plaintiff
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`again. Plaintiff called and texted Wong over several days but Wong never responded and her
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`calls all went direcly to voicemail (Violante Affidavit 12/20/2021 ¶9; Violante Affidavit
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`1/6/2022 ¶20, 21).
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`Plaintiff Did Not Know That Wong Had Been “Devastated”
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`What plaintiff did not know, until she went to Citipups to report Louie stolen to
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`the microchip registry, was that Wong had been in the pet shop on July 25, 2021 before plaintiff
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`purchased Louie and Wong had left to confer with her husband. When Wong returned to the
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`store later, plaintiff was already purchasing Louie (2nd Angie Affidavit ¶6, 7). The store
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`employee, Argelio Vasquez, has submitted an affidavit stating that Wong was gone for more than
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`an hour and that she did not respond to his texts. (Affidavit of Argelio Vasquez, Doc #51.)
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`On December 20, 2021, plaintiff learned from Wong’s sworn admission that when
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`she could not buy Louie on July 25th, Angie and her children were “devastated” (2nd Angie
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`Affidavit ¶8; Statement of Material Facts ¶8). This was obviously Wong’s motive in
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`befriending plaintiff on July 27, 2020 and thereafter. Plaintiff was unaware of any of this. Had
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`she known, she would have steered clear of Angie Wong (Violante Affidavit 1/6/2022 ¶4).3
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`Angie’s devastation at losing Louie in the pet shop, plows a fairly large hole in her assertion that
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`her motivation was only to do plaintiff a “favor” because plaintiff “begged her”. It is apparent
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`that Wong’s eagerness to help plaintiff out with her temporary work issue was a ploy to get
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`possession of the dog she had wanted all along.
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`Another thing that plaintiff did not know, was that Angie left for Miami on
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`August 13, 2020. Wong had told plaintiff and Alicia that she was going to Florida at the end of
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`August (See text from Alicia, Exhibit “C” to Violante Affidavit 1/6/2022, wherein Alicia states,
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`about Angie: “I remember her saying they weren’t going to Florida until the end of the month.
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`Did they go early?”). It is apparent that Wong moved up her departure from New York in order
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`to abscond with Louie.
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`While Wong was posing as a nice person to plaintiff, she told plaintiff that they
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`should have coffee in Brooklyn, near plaintiff’s apartment, because her daughter, Maddy was
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`3 Defendant’s Memorandum of Law (p.2) states that “Violante purchased Louie on July
`25, 2020, knowing that Angie and her children also wanted to buy him” citing 2nd Angie
`Affidavit ¶5-¶8. Wong’s affidavit does not state that. But if Wong believed it to be true, it
`strengthens plaintiff’s claim. Wong wanted revenge.
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`attending a summer day camp in Brooklyn (Violante Affidavit 1/6/2022, ¶12).
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`No doubt, Wong told the police a story similar to the one she tells here, though
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`she probably did not tell the police about how she and her children were devastated on July 25,
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`2020, when plaintiff bought the dog they wanted. In “Version 1” of the purported police report,
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`the “further investigation” is apparently based on communication with Wong, who put the same
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`spin on the texts as in her affidavit.
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`Plaintiff did drop of Louie “willingly”, but for dog-sitting a few days. Plaintiff
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`was aware that Wong would be going to Florida, at some point, but not on August 13th and not
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`with plaintiff’s dog! The comment that plaintiff did not do her “due diligence” is cruelly off the
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`mark. Wong hurriedly changed her plans to abscond with plaintiff’s dog.
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`ANGIE WONG HAS NO PROOF
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`Angie Wong has a story, but no proof beyond her own internally inconsistent
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`testimony. She does not challenge plaintiff’s purchase of Louie. In fact she is a witness to it (2nd
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`Angie Affidavit ¶8). It is undisputed that plaintiff bought and owned the dog as of July 27, 2020.
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`Plaintiff claims that the dog was gifted to her, but she has no proof.
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`Wong makes perfectly clear that she and her children4 were devastated that they
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`were unable to buy the dog on July 25, 2020. Yet, she invited the woman who bought him and
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`4 Plaintiff avers that she never saw Wong’s son in the store, at her apartment or anywhere
`else. Wong had told plaintiff that he was with his father in Miami.
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`the dog they wanted, to her house for the play-date? But for the opportunity to take the dog, why
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`would she do that?
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`Wong alleges that plaintiff, who bought Louie and took him home on July 27,
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`2020, having paid $3,500.00 for him, ten days later “begged” Wong, a veritable stranger, whom
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`she knew had never owned a dog before, to take her dog away, because she thought they would
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`make a “good fit”? That is simply not credible.
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`In order to prove a valid inter vivos gift, the proponent of the gift must prove, by
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`clear and convincing evidence, an intent on the part of the donor to make a present transfer,
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`delivery of the gift to the donee and acceptance by the donee. Reif v. Nagy, 175 A.D.3d 107,129,
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`106 N.Y.S.3d 5, 22 (1st Dept. 2019); Redstone v. Herzer, 162 A.D.3d 583, 584, 80 N.Y.S.3d 28,
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`29 (1st Dept. 2018); Gruen v. Gruen, 68 N.Y.2d 48, 53, 505 N.Y.S.2d 849, 496 N.E.2d 849
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`(1986). Plaintiff clearly did not intend to transfer ownership of the dog she had just purchased to
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`Wong and Wong has not and cannot prove that. Wong’s interpretation of ambiguous texts and
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`emoji’s do not constitute proof; and certainly not clear and convincing proof. Plaintiff’s text
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`stating “I couldn’t say goodbye or I’d cry” was an expression of sadness at separating from her
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`dog for one night. Every dog owner knows this.
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`Wong’s August 13th text asking plaintiff if she can keep Louie and pay for him is
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`clear evidence that she herself did not believe that she owned him. Her statement that she had
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`just purchased airline tickets, but not that she was leaving town that very day is further proof that
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`she was stealing the dog and that plaintiff did not know of Wong’s travel plans. Wong’s conduct
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`after plaintiff did not accede to her request to purchase the dog is further proof of her guilt and
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`liability for conversion. She absconded with the dog and never contacted plaintiff again, despite
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`plaintiff’s numerous heartfelt attempts to make contact.
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`It is respectfully submitted that defendant Agie Wong has not and cannot offer
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`credible admissible proof that plaintiff had the requisite intent to make a gift of her dog Louie to
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`Wong, at any time. Moreover, Wong’s conduct, particularly on and after August 13, 2020, is
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`consistent with conversion and not at all consistent with a gift.
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`Wong’s Documentary Evidence is Suspect
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`As with Wong’s exhibits annexed to her first affidavit, sworn to November 4,
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`2020 (Doc #4) (like her redacted lease and voter registration card), Wong’s exhibits are vague or
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`manipulated. Her photograph of Louie’s eyedrops (Exhibit “6”, Doc # 43) and his veterinary and
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`expense records (Exhibit “7”, Doc # 44) do not display his name or the veterinarian’s name. The
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`first page of Exhibit “7” is intentionally blurred and merely displays a total of $5,808.72. Even
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`the photograph of “Louie and his sister Daisy” does not show their faces! It seems that Wong’s
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`goal in attaching exhibits is to mislead. To provide dis-information. She claims to have
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`expended $11,544 on “housekeeping”, but provides no proof of what that means (2nd Angie
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`Affidavit ¶43).
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`ANGIE WONG CANNOT BE AWARDED POSSESSION OF LOUIE
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`Defendant also engages in the practice of mis-citing cases. In defendant’s
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`Memoranda of Law dated November 11, 2020 (Doc #5) and January 19, 2021 (Doc #34)
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`defendant cited countless cases of negligent infliction of emotional distress and negligent loss or
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`destruction of a pet and then concludes that defendant had demonstrated that the law of New
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`York does not recognize intentional infliction of emotional distress involving pets. Defendant
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`engages in a similar tactic here.
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`In defendant’s Supplemental Memorandum dated December 20, 2021, a different
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`legerdemain predominates. Here, defendant cites matrimonial cases or that involve lovers or
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`roommates, as if they were applicable to the facts presented here; a theft by a deceitful stranger.
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`Eva Violante and Angie Wong weren’t married, they weren’t lovers, they weren’t roommates and
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`they weren’t even friends, although Eva was tricked into thinking they were.
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`Defendant suggests that the “best for all concerned” standard should be applied to
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`this case. But that is the standard applied when the litigants are or were married, living together
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`or otherwise have a good faith argument that they each have some ownership interest in the
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`animal. Travis v. Murray, 42 Misc.3d 447,452, 977 N.Y.S.2d 621 (Sup Ct. NY Cty. 2013), was a
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`custody case in a divorce proceeding. Raymond v. Lachmann, 264 A.D.2d 340, 695 N.Y.S.2d
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`308 (1st Dept. 1999) arose out of the litigants’ “shared living situation”.
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`Finn v. Anderson, 64 Misc.3d 273, 101 N.Y.S.3d 825 (City Ct. Jamestown,
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`Chautauqua Co. 2019) involved a 10 year old “outdoor cat” that was innocently taken indoors by
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`the plaintiffs, who were unaware the cat was owned by a neighbor, in good faith. The court held
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`for the defendant, who was the cat’s original owner for 10 years. In Ramseur v. Askins, 44
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`Misc.3d 1209(A), 997 N.Y.S.3d 101 (Civ. Ct. Bronx Co. 2014), the plaintiff had purchased the
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`dog for his granddaughter, then left it with his mother who left it with her sister. Plainitff sought
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`the return of the dog 2 years later, ostensibly, in order to breed it. In both LeConte v. Lee, 35
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`Misc.3d 286, 935 N.Y.S.2d 842 (Civ. Ct. N.Y. Co. 2013) and Shaloo v. Zarrour, 70 Misc.3d
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`1218(A), 139 N.Y.S.3d 792 (Sup. Ct., Queens Co. 2021)5 the litigants had been cohabiting in
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`romantic relationships.
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`In none of the cases cited by defendant was the pet stolen or taken by a stranger or
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`acquaintance of the animal’s owner. In such a case, it is submitted that the key to the right to
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`possession can only be title. A thief who transports the chattel to another state, refusing to
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`surrender it to its rightful owner cannot be allowed to acquire good title merely by spending
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`money on it while the true owner immediately commenced a lawsuit to recover the chattel.
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`Indeed, that is what defendant’s argument is in her Reply Memorandum of Law at
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`p.8: “Angie has a greater possessory right in the dog because of the huge disparity in the length
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`of time that she has owned the dog and the amount of money that she has spent taking care of
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`him” (Emphasis added). Angie Wong has never “owned the dog” for any length of time. She is
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`not the owner. A thief does not acquire good title. The “huge disparity of time” was occasioned
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`by Wong’s decision to make a pre-answer motion rather than serving an answer. Wong’s
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`expenditure of money while not returning him to his rightful owner cannot create title.
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`5 In Shaloo, the court, in attempting to determine the superior possessory right in the
`chattel, reviewed defendant’s documents and noted that defendant’s payment documents did not
`identify the payee as a dog breeder or prior owner of the dog. Plaintiff does have such sales
`documents. (See, plaintiff’s Exhibits “A” and “B” to her Affidavit sworn to on January 7, 2021,
`Docs #27 and #28, as well as Exhibits “C” and “D” Docs #29 and #30).
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`PLAINTIFF SHOULD BE ALLOWED TO FREELY LITIGATE
`ALL OF THE CLAIMS SET FORTH IN HER COMPLAINT
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`As defendant’s Reply Memorandum states, but then discards, the issue of the
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`merit of plaintiff’s Intentional Infliction of Emotional Distress claim and the propriety of
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`exemplary damages was briefed by both parties one year ago. Plaintiff respectfully refers the
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`Court to her Memorandum of Law in Opposition to Motion to Dismiss (Doc #31).
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`Plaintiff would like to direct the Court’s attention to an anomalous situation in the
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`development of the law in New York concerning companion animals. It is one that defendant is
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`expertly exploiting.
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`As promoted in the decisions of Travis v. Murray, Raymond v. Lachmann and
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`many other relatively recent cases, the law concerning custody of pets has evolved greatly in
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`recent years. Travis v. Murray refers to the “trend in New York jurisprudence towards so-called
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`‘de-chattelization ‘of household pets” 42 Misc.3d at 455. In Raymond v. Lachmann the First
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`Department panel expressly recognized “the cherished status accorded to pets in our society, the
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`strong emotions engendered by disputes of this nature, and the limited ability of the courts to
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`resolve them satisfactorily . . .) 264 A.D.2d at 341.
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`In Feger v. Warwick Animal Shelter, 59 A.D.3d 68, 870 N.Y.S.2d 124 (2d Dept
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`2008), the Second Department noted that: “[c]ompanion animals are a special category of
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`property and are afforded many protections under the law . . .” 59 A.D.3d at 71; “The reach of
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`our laws has been extended to animals in areas which were once reserved only for people. Id.
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`Pet custody cases abound in matrimonial and other courts and the law has
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`evolved. Governor Hochul recently signed legislation amending the Domestic Relations Law to
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`recognize the interests of the pet. The First Department recognized “the strong emotions
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`engendered by disputes of this nature” in Raymond v. Lachmann , and defendant appears to argue
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`that Wong has a greater possessory right to Louie because Wong’s family “loves” him.
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`Yet, at the same time, defendant argues fiercely that in determining whether to
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`compensate a party for the loss of a pet, only market value may be considered, not loss of
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`companionship or emotional distress, citing cases from the last century or the century before
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`that.6 It is apparent that legal concepts surrounding pets in matrimonial cases have evolved,
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`while other aspects of law concerning companion animals, that may not be revisited as frequently
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`in the caselaw, stagnates. It does not make sense that our appellate courts recognize the “strong
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`emotions” engendered by pet custody cases, but should preclude recovery in an Intentional
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`Infliction case, as defendant argues here. And they don’t.
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`As pointed out in plaintiff’s Memorandum in Opposition dated January 7, 2021
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`(Doc# 31), when the court in Kyprianides v. Warwick Valley Humane Society, 59 A.D.3d 600,
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`601, 873 N.Y.S.2d 710 (2d Dept. 2009) held that “[u]nder the circumstances of this case, the
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`6 Defendant clearly enjoys quoting from Travis v. Murray or from cases citing to Travis
`v. Murray, without acknowledging that the language quoted is in the decision precisely to
`highlight the antiquated notions that persist in our law. Justice Cooper has been lauded for his
`progressive decision in Travis, although his decision is replete with juicy quotes for those
`wishing to wallow in 19th Century concepts pertaining to domestic animals.
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`defendant’s conduct in euthanizing some of the animals was not sufficiently outrageous and
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`egregious to support a claim for the intentional infliction of emotional distress” it implicitly
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`indicated that under the circumstances of a different case, the claim would survive. There is no
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`general rule in New York that excepts animals from an Intentional Infliction claim.
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`Similarly, there is no rule that planning and executing a scheme to steal someone
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`else’s beloved dog engenders any less malice or reckless or willful disregard of a plaintiff’s right,
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`than the conversion of other items of value.
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`PLAINTIFF SHOULD BE GRANTED POSSESSION PENDENTE LITE
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`But for defendant’s removal of Louie from the State of New York to the State of
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`Florida, plaintiff could have had the Sheriff seize him, reclaiming the chattel pursuant to CPLR
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`§7102 et seq. By reason of the current status of this action and all of the facts now before this
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`Court, in the event that plaintiff is not granted summary judgment, she respectfully requests that
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`she be granted custody and possession of her dog, Louie, pendente lite, under the same
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`conditions prescribed under CPLR Article 71.
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`CONCLUSION
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`By reason of the foregoing, plaintiff should be granted summary judgment on
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`liability, a judgment directing that her dog Louie be returned to her and a hearing scheduled to
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`assess compensatory and exemplary damages.
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`FILED: KINGS COUNTY CLERK 01/10/2022 08:27 PM
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`Dated: Scarsdale, New York
`January 10, 2022
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`_____________________________
`DANIEL G. HEYMAN, ESQ.
`Attorney for Plaintiff
`670 White Plains Road - Suite 121
`Scarsdale, New York 10583
`(914) 723-5500
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`CERTIFICATE OF COMPLIANCE
`Pursuant to 22 NYCRR 202.8-b
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`DANIEL G. HEYMAN, an attorney duly admitted to practice law in the State of
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`New York, subscribing and affirming as true under penalties of perjury states as follows:
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`1.
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`The attached Reply Memorandum of Law was prepared on a computer
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`using word processing software which includes a word counting function that provides a tally of
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`the total number of words in the document.
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`2.
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`Based on the foregoing, the attached Affidavit contains a total of 4,133
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`words, exclusive of the caption and signature block and it is therefore in compliance with the
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`limits imposed by §202.8-b of the Uniform Rules for the Trial Courts.
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`Dated: Scarsdale, New York
`January 10, 2022
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`____________________________
`DANIEL G. HEYMAN, ESQ.
`Attorney for Plaintiff Eva Violante
`670 White Plains Road, Suite 121
`Scarsdale, New York 10583
`(914) 723-5500
`dheyman@danheyman.com
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`FILED: KINGS COUNTY CLERK 01/10/2022 08:27 PM
`NYSCEF DOC. NO. 63
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`Index No.: 517535
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`Year:2020
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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF KINGS
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`
`EVA VIOLANTE,
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`-against-
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`Plaintiff,
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`ANGIE WONG a/k/a ANGIE WONG SIE YING,
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`Defendant.
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`
`
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`PLAINTIFF’S REPLY MEMORANDUM OF LAW IN
`OPPOSITION TO DEFENDANT AND IN SUPPORT
`OF SUMMARY JUDGMENT FOR PLAINTIFF
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`
`
`DANIEL G. HEYMAN, ESQ.
`Attorney for Plaintiff
`670 White Plains Road - Suite 121
`Scarsdale, New York 10583
`(914) 723-5500
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