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Original Message:

Re: Manhattan Club Lawsuit (by Fibo N.):

More extracts from the MEMORANDUM OF LAW IN OPPOSITION, Aug.19, 2016

"THE RESPONDENT ENTITIES HAVE UNCLEAN HANDS

... Equitable relief is unavailable to a party who comes to the Court with unclean hands... Unclean hands exist when a party is “participating in a course of conduct of deception and deceit.” .. The doctrine of unclean hands applies against a party who is “guilty of immoral, unconscionable conduct,” where such misconduct is directly related to the subject matter in the litigation, and the party seeking to invoke the doctrine was harmed by the misconduct.

Having already spent over $1.7 million on legal fees since July 2015, when NYAG cross-moved and put all Respondents on notice that NYAG sought to sequester Urban’s assets, the Respondents knowingly reduced the amount of funds available for a future restitution award. Their effort to double-dip at the expense of timeshare purchasers should not be permitted as it would harm the victims. ..

...NYAG has a strong interest in disgorging bad actors from ill-gotten gains."