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More extracts from Memorandum of Law in Opposition, Aug. 19, 2016. Love to share! Since January 2015, Respondents Have Withdrawn Millions of Dollars from Urban’s Bank Accounts to Pay Legal Fees and Other Expenses that Are Unrelated to the Timeshare Association. Between January 2015 and May 2016, Urban disbursed $3.5 million to T. Park’s lender, Capital Source Bank, also known as Pacific West Bank; and additional $2.2 million to four law firms: Winston & Strawn LLP, Katsky Korins LLP, and Bracewell LLP and DLA Piper LLP (US). Upon information and belief, Respondent Urban’s payments to those law firms reflect Urban’s payment of the legal fees for all Respondents, including the individually named Respondents... ... Respondent Individuals have not attempted to show a lack of alternative sources to pay their legal fees. No affidavit or financial statement has been filed by any of the Respondent Individuals... At least one respondent, Ian Bruce Eichner, may be able to pay his own legal fees, as he may be worth over $275 million. Urban is paid approximately $540,000 per month by the Timeshare Association... The Timeshare Association is funded in turn by timeshare owners’ payments of annual maintenance fees, and other miscellaneous income that includes revenue from the rentals of rooms by the general public... The timeshare owners’ payments of common charges, like their mortgage payments, were procured by fraudulent sales... This instance of misconduct is established by the report NYAG ran off of the Manhattan Club’s internal database that demonstrated hundreds of reservations by the general public more than two days in advance of a check in date... This misrepresentation is material because prospective purchasers likely would not have bought timeshare interests if they had known it was possible, and is much cheaper, to rent rooms at the Manhattan Club rather than becoming an “owner.” Thus, the prior Orders were supported by evidence of fraud. ...The Respondent Entities’ primary income stream is Respondent Urban’s $6.4 million annual fee, paid by the Timeshare Association. The Timeshare Association in turn is funded by timeshare owners’ annual maintenance fee and tax payments, and miscellaneous income, which includes Urban’s rentals of Club rooms to the general public... Respondents T. Park and O. Park generate approximately $4,000 per month in revenue through certain timeshare owners’ mortgage payments on loans issued by T. Park and O. Park in connection with the sale of timeshare interests... ...Between July and December 2014, the parties entered into seven stipulations that were subsequently approved by the Court, that allowed T. Park, O. Park and Marketing Group to make payments from specified bank accounts for enumerated purposes, such as paying their employees’ salaries and wages, and trade payables. .. However, NYAG was concerned that Respondents were violating the spirit, if not the plain terms of the first three stipulations by paying consultants, in addition to employees, and reimbursing Respondent Lager for a $560 dinner, a $250 lunch, $281 for maintenance of a Porsche, and the $2,500 annual membership fee for his American Express Centurion Card bill. .. Accordingly, and because each so-ordered stipulation reduced the funds being preserved in the frozen accounts, in December, the parties agreed, pursuant to the seventh so-ordered stipulation, that Respondents tender $550,000 to NYAG to hold in escrow in exchange for allowing them to pay certain expenses from the frozen funds. The Frozen Funds are Tainted by Fraud and the Escrowed Monies Are Being Held for the Benefit of Others The Respondent Entities claim that the frozen funds “belong” to them. .. However, the vast majority of funds they seek are either tainted by fraud or is held in escrow for the benefit of others. The corporate funds are directly or indirectly from timeshare owners..." https://iapps.courts.state.ny.us/fbem/DocumentDisplayServlet?documentId=ovMjFpy6NexIU4/QSkN3Gg==&system=prod