SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS, CRIMINAL TERM, PART --------------x- THE PEOPLE OFTHE STATE OFNEWYORK : NOTICE OF MOTION Ind. No. 13625196 -against- JOHN O'HARA, Defendant. PLEASE TAKE NOTICE that, upon the annexed Affirmation of JOEL B. RUDIN and accompanying Appendix of Exhibits, and upon the annexed Affidavit of JOHN O'HARA, and upon aII prior proceedings herein, the undersigned will move this Court, at the Criminal Term, at the Courthouse, 320 Jay Street, Brooklyn, New York LI20I, on February 18, 2015, at 9:30 â.D., or as soon thereafter as counsel may be heard, for an order, pursuant to C.P.L. $S 440.10(1Xg) and (h), and the Free Speech, Right of Petition, Equal Protection, and Due Process guarantees of the New York State and United States Constitutions, vacating John O'Hara's judgment of conviction in this matter, granting an evidentiary hearing to resolve any disputed issues of fact, or granting other and further relief as would be just and proper. ours, etc., Ø(c L B. RUDIN Offrces of Joel B. Rudin Fifth Avenue, 10th Floor New York, New York 10020 (2r2) 752-7600
[email protected] Attorney for defendo,nt John O'Hara Dated: New York, New York January 6,2OI5 To: Kenneth Thompson, Esq. District Attorney of Kings County 350 Jay Street Brooklyn, New York 11201 2 RUDIN AFFIRMATIOI{ SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS, CRIMINAL TERM, PART - x THE PEOPLE OF THE STATE OF NEW YORK AFFIRMATION Ind. No. 13525196 -against- JOHN O'HARA, Defendant.