American Picture House Corp. (APHP)

[seven77]

Could the action today have anything to do with this right here?

We represent MacGregor and LDSI, Defendants and Counterclaim-Plaintiffs in the abovereferenced action, and write, pursuant to Rule 24 of the Rules of the Commercial Division of the
Supreme Court (Advance Notice of Motions), to advise Your Honor – on notice to counsel for
Sprung, Plaintiff and Counterclaim-Defendant in the above-referenced action – of MacGregor’s
and LDSI’s intention to bring a joint motion to disqualify Sprung’s counsel. This letter also
outlines some of the issues related to the anticipated motion.1
With this case still at an early stage (e.g., discovery has only just begun), MacGregor and LDSI
intend to move jointly to disqualify Plaintiff’s counsel because:
(i) Plaintiff’s counsel had prior attorney-client relationships with each of MacGregor
and LDSI, including in connection with a highly sensitive criminal matter;
(ii) Those prior representations are substantially related to Plaintiff’s counsel’s
representation in this action; and
(iii) Plaintiff’s interests and those of MacGregor and LDSI are materially adverse.

https://iapps.courts.state.ny.us/nyscef/ViewDocument?docIndex=LhrN3L56ZuHtzLdNWUvg5A==