I 2016 123456 DEPARTMENT OF HOUSING PRESERVATION AND DEVELOPMENT CITY OF GOTHAM

I 2016 123456 department of housing preservation and

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I-2016-123456 DEPARTMENT OF HOUSING PRESERVATION AND DEVELOPMENT, CITY OF GOTHAM, Respondent. STATE OF NIRVANA ) COUNTY OF BIG ) ss. CITY OF GOTHAM ) H. CHARLES GREENBERG, Esq., pursuant to State of Nirvana CPLR 2106 and subject to the penalties for perjury, duly affirms the following to be true and accurate to the best of my knowledge: 1. I am an attorney duly admitted to the practice of law in the State of Nirvana. I am a senior associate in the law firm of Miranda, Gutekunst & Gerstman, PLLC. 2. I represent Harley Davison (“Davison”), the petitioner in this action. 3. I submit this affirmation in support of Davison’ s request for an order to show cause seeking an order vacating a determination of the respondent made on May 16, 2018 denying Davison the right to succeed to the leasehold of a rent-controlled apartment, to wit: 126-34 West Huron Street, Apt. #110, City of Gotham, State of Nirvana. 4. The petitioner is seeking to proceed by way of order to show cause rather than notice of motion because the respondent has commenced an eviction proceeding, which, if successful, would result in immediate harm to the petitioner and endanger his/her well-being.
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2018-2019 Mock Trial Case (Final Version Nov 5 2018) Includes all corrections made as of FEB 7, 2019 (rev. 2018.12.14) 84-R1 5. The petitioner designates Big County as the venue of this special proceeding. The basis of venue is that the respondent’s determination denying Davison the right to succeed to the leasehold of the rent- controlled apartment was made in Big County. 6. No previous application for the same or similar relief herein prayed for has been made. WHEREFORE, it is respectfully requested that this court issue an order directing the respondent to show cause wh y the respondent’s determination made on May 16, 2018 should not be vacated, why an order staying eviction should not be granted and why such other and further relief as may be just and proper should not be granted. DATED: Gotham, Nirvana August 15, 2018 H. CHARLES GREENBERG, Esq.
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2018-2019 Mock Trial Case (Final Version Nov 5 2018) Includes all corrections made as of FEB 7, 2019 85 EXHIBIT __________ STATE OF NIRVANA SUPREME COURT : COUNTY OF BIG IN THE MATTER OF THE APPLICATION OF HARLEY DAVISON , Petitioner, VERIFIED PETITION -vs- Index No. I-2016-123456 DEPARTMENT OF HOUSING PRESERVATION AND DEVELOPMENT, CITY OF GOTHAM, Respondent. TO THE SUPREME COURT OF THE STATE OF NIRVANA FOR BIG COUNTY The petition of HARLEY DAVISON complaining of the respondent Department of Housing Preservation and Development of the City of Gotham respectfully alleges that: 1. This is a special proceeding brought pursuant to Article 78 of the Nirvana Civil Practice Law and Rules. 2. Pursuant to CPLR §§ 7804 and 506[b], venue of this proceeding is the County of Big because this is where the determination of the respondent being challenged was made. 3. Petitioner is a resident of the City of Gotham and resides at 126-34 West Huron Street, Apt. #110, Gotham, Nirvana. The leaseholder of the apartment is Barbra Stone, the petitioner’s great aunt. 4. Respondent is an agency of the City of Gotham and is located at 1788 Constitution Drive, Gotham, Nirvana.
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