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EXHIBIT(S)

Document Liting Zhang v. Law Office of Jingcong Wu, P.C. et al, 151220/2021, 57 (N.Y. Sup. Ct., Richmond County Jan. 4, 2022)
total Overdraft unpaid Principal Balance is:
03-01-21. paid to or after on interest will per void for be charge due are
JP Morgan TBillick 5323 325070760 Loan Chase Law
instructions will and be the for sent required recording funds have after been have you received with complied and processed.
Theinformationcontainedin this facsimilemessageis a privilegedandconfidentialinformationintendedfor theuseof theaddresseelistedabove.
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AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION

Document Liting Zhang v. Law Office of Jingcong Wu, P.C. et al, 151220/2021, 54 (N.Y. Sup. Ct., Richmond County Jan. 4, 2022)
I am an attorney-at-law in the State of New York and Co-Managing Partner of the law firm of Riker, Danzig, Scherer, Hyland & Perretti LLP (“Riker Danzig”), attorneys for plaintiff Liting Zhang (“Zhang”) in the above-captioned action.
Attached hereto as Exhibit 1 is a true and accurate copy of the June 28, 2021 Complaint filed by Zhang in this action.
Attached hereto as Exhibit 2 is a true and accurate copy of the March 31, 2021 email chain at issue in this action.
Attached hereto as Exhibit 3 is a true and accurate copy of the March 31, 2021 fraudulent payoff letter at issue in this action, with the loan and bank account numbers redacted.
Attached hereto as Exhibit 4 is a true and accurate copy of the July 9, 2021 Complaint for Declaratory Relief filed in the action styled Alps Property & Casualty Insurance Company v. Timothy Billick, et al., Case No. 2:21-cv-00916, pending in the United States District Court for the Western District of Washington.
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EXHIBIT(S)

Document Liting Zhang v. Law Office of Jingcong Wu, P.C. et al, 151220/2021, 58 (N.Y. Sup. Ct., Richmond County Jan. 4, 2022)
4.15 Onor about June 17, 2021, ALPS issued a letter to Billick advising that it agreed to provide him with a defense of the actual or potential claims arising out of the wire fraud allegations subject to an express reservation ofrights.
or criminal, malicious, fraudulent, dishonest, Any intentionally wrongful or harmful act, error or omission committed by, at the direction of, or with the consent of an Insured, or any Personal Injury arising from or in connection with such conduct, subject to Section 6.A.
The ALPS Policy defines “Damages” to mean any monetary award by way of judgmentorfinal arbitration, or any settlementor any civil liability which may be imposed upon the insured under section 813(a) of the Federal Fair Debt Collection Practices Act.
5.9 The ALPS Policy specifically excludes coverage for any claim arising from a dishonest, fraudulent, criminal, malicious, or intentionally wrongful act, error, or omission committed by, at the direction of, or with the consent of an insured.
1 Ragetetscrr: 5.12 There is an actual justiciable controversy as to whether Billick converted, misappropriated, wrongfully disbursed, or negligently supervised funds or property when he wired fundsto a fraudulent entity in a foreign bank.
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EXHIBIT(S)

Document Liting Zhang v. Law Office of Jingcong Wu, P.C. et al, 151220/2021, 55 (N.Y. Sup. Ct., Richmond County Jan. 4, 2022)
Companies are business entities, along with their co- conspirators and/or aiders and abettors, whose identities are unknown that may bear liability to Zhang for the damages and injuries set forth herein (collectively the
On May 20, 2021, a new attorney for the Sellers sent a letter to the Huang Firm stating that Zhang is "short funds in the amount of $529,950.08" from the closing and demanding immediate payment.
The Email Parties' breach of the duty of care has proximately caused Zhang to suffer damages in that the Fraudsters have absconded with the Proceeds, the EastWest Mortgage still encumbers the Property, and the Sellers have 5284725v2 of
The Closing Parties owed a duty of care to Zhang to ensure Loan Proceeds were properly disbursed at the Transaction.
Zhang seeks judgment against the Billick Firm for compensatory damages, interest, costs of suit, including reasonable attorney's fees, and for such other relief as the Court deems just and equitable.
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NOTICE OF MOTION

Document Liting Zhang v. Law Office of Jingcong Wu, P.C. et al, 151220/2021, 50 (N.Y. Sup. Ct., Richmond County Jan. 4, 2022)
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MEMORANDUM OF LAW IN OPPOSITION

Document Liting Zhang v. Law Office of Jingcong Wu, P.C. et al, 151220/2021, 53 (N.Y. Sup. Ct., Richmond County Jan. 4, 2022)
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EXHIBIT(S)

Document Liting Zhang v. Law Office of Jingcong Wu, P.C. et al, 151220/2021, 56 (N.Y. Sup. Ct., Richmond County Jan. 4, 2022)
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ANSWER

Document Liting Zhang v. Law Office of Jingcong Wu, P.C. et al, 151220/2021, 47 (N.Y. Sup. Ct., Richmond County Dec. 10, 2021)
Denies knowledge or information sufficient to form a belief as to the allegations contained in paragraph “4” of the Complaint and refers all questions of law and fact to this Court.
Denies knowledge or information sufficient to form a belief as to the allegations contained in paragraph “5” of the Complaint and refers all questions of law and fact to this Court.
Denies knowledge or information sufficient to form a belief as to the allegations contained in paragraph “6” of the Complaint and refers all questions of law and fact to this Court.
Plaintiff’s claims are barred by the doctrines of laches, estoppel, unclean hands, assumption of risk and/or waiver based upon the facts as they are related to the action herein.
WHEREFORE, the Defendant AL DiGERONIMO demands judgment as follows: (a) Dismissing the complaint herein it its entirety with prejudice; and (b) That Judgement be entered on his Cross Claims; and (c) For Attorneys’ fees and costs in an amount to be determined; and (d) For such other and further relief as this Court deems just, proper and equitable.
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AFFIRMATION/AFFIDAVIT OF SERVICE

Document Liting Zhang v. Law Office of Jingcong Wu, P.C. et al, 151220/2021, 45 (N.Y. Sup. Ct., Richmond County Oct. 14, 2021)
Thornton, Shirley 18 years is over I served a copy of Defendant's of Defendant's and Failure action, 14, 2021, in Support Suppert Conveniens, of of sworn, duly being resides and age the within Notice Motion to Dismiss Motion to Dismiss A Claim to State deposes in Westchester of Motion, with Lack for upon: and says: County, Affidavit Exhibit
on October That of Tim Billick, Affirmation and Memorandum of Law In Forum Non Jurisdiction, Al Digeronimo 112 Forest Staten Island, Unit Street,
Class Mail First via in a postpaid, of custody properly the United at addresses the addressed Postal States that for envelope Service a true purpose by depositing under in an official depository of New York within the State copy the for same of exclusive that purpose.
enclosed care and Shirley Th ton Sworn 14th me this to before 2021 of October, day
Qualified in Westchester Commission Expires: of York County December 31, 2022
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EXHIBIT(S)

Document Liting Zhang v. Law Office of Jingcong Wu, P.C. et al, 151220/2021, 42 (N.Y. Sup. Ct., Richmond County Oct. 14, 2021)
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MEMORANDUM OF LAW IN SUPPORT

Document Liting Zhang v. Law Office of Jingcong Wu, P.C. et al, 151220/2021, 43 (N.Y. Sup. Ct., Richmond County Oct. 14, 2021)
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AFFIDAVIT OR AFFIRMATION IN SUPPORT OF MOTION

Document Liting Zhang v. Law Office of Jingcong Wu, P.C. et al, 151220/2021, 40 (N.Y. Sup. Ct., Richmond County Oct. 14, 2021)
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NOTICE OF MOTION

Document Liting Zhang v. Law Office of Jingcong Wu, P.C. et al, 151220/2021, 39 (N.Y. Sup. Ct., Richmond County Oct. 14, 2021)
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41

Document Liting Zhang v. Law Office of Jingcong Wu, P.C. et al, 151220/2021, 41 (N.Y. Sup. Ct., Richmond County Oct. 14, 2021)

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26

Document Liting Zhang v. Law Office of Jingcong Wu, P.C. et al, 151220/2021, 26 (N.Y. Sup. Ct., Richmond County Oct. 12, 2021)

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