Plaintiff instituted this action for damages against defendant Gittens, his former bookkeeper who had embezzled large sums of money from him, and against Maria and Walter Richardson, Gittens' daughter and son-in-law, as well as to impress a constructive trust and lien on real and personal property acquired with these funds. In response to plaintiff's cross-motion for default judgment, defendant Gittens submitted an affirmation by her attorney requesting leave to file a late...
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