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  • Mangino Chevrolet, Inc v. Eric Staring Commercial - Business Entity document preview
  • Mangino Chevrolet, Inc v. Eric Staring Commercial - Business Entity document preview
  • Mangino Chevrolet, Inc v. Eric Staring Commercial - Business Entity document preview
  • Mangino Chevrolet, Inc v. Eric Staring Commercial - Business Entity document preview
  • Mangino Chevrolet, Inc v. Eric Staring Commercial - Business Entity document preview
  • Mangino Chevrolet, Inc v. Eric Staring Commercial - Business Entity document preview
  • Mangino Chevrolet, Inc v. Eric Staring Commercial - Business Entity document preview
  • Mangino Chevrolet, Inc v. Eric Staring Commercial - Business Entity document preview
						
                                

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FILED: FULTON COUNTY CLERK 04/25/2024 10:36 AM INDEX NO. EF2019-07198 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 04/25/2024 STATE OF NEW YORK SUPREME COURT COUNTY OF FULTON MANGINO CHEVROLET, INC., SUBPOENA DUCES TECUM Plaintiff, -against- Index No.: 07198 ERIC STARING, Defendant. TO: Zappone Chrysler Jeep Dodge RAM 1780 U.S. Route 9 Clifton Park, New York 12065 GREETINGS: WE COMMAND YOU, that all business and excuses being laid aside, that you produce to 450 New Karner Road, Albany, New York 12212, on or before the day of June, 2019 at 10:00 o'clock in the forenoon, true and complete copies of the following: 1. Copies of all documents, electronically stored information, employment records, financial records and data, and other recordsrin connection with the Defendant, Eric Staring's, employment, sale of vehicles and/or performance of services on your behalf to customers beginning December 5, 2016, through the present. 2. Copies of all correspondence and/or other communications, including, but not limited to, letters, e-mails and text message,.whether in hard copy or electronic format, to or from the Defendant, Eric Staring, regarding the sale of vehicles and/or performance of services on your behalf or to your customers beginning December 5, 2016, through the present. 3. Copies of all employment records maintained for the Defendant, Eric Staring, including but not limited to, employment contracts and/or agreements, W-2's, returned paychecks, FILED: FULTON COUNTY CLERK 04/25/2024 10:36 AM INDEX NO. EF2019-07198 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 04/25/2024 confirmations of direct deposits of paychecks, and all other documents referencing the terms of your employment of, and compensation paid to, the Defendant, Eric Staring. Failure to comply with this subpoena is punishable as a contempt of Court and shall make you liable to the person on whose behalf this subpoena was issued for a penalty not to exceed Fifty and 00/100 ($50.00) Dollars and all damages sustained by reason of your failure to comply. Please take notice that compliance with this subpoena may be made by mailing to the undersigned the items required to be produced herein, certified as complete and accurate by the person in charge of said records, and no personal appearance to certify such item or items shall be required unless the Court shall order otherwise. DATED: May 16, 2019 Very truly yours, T WNE, N & PARTNERS, P.C. By: Ja e . owne, Jr., Esq. Att - for Plaintiff P.O. Box 15072 450 New Karner Road Albany, New York 12212-5072 Tel. No.: (518) 452-1800 cc: David M. Siegal, Esq. Attorneys for Defendant 16 Corporate Woods Boulevard Albany, New York 12211-2350 (518) 431-1000 2 FILED: FULTON COUNTY CLERK 04/25/2024 10:36 AM INDEX NO. EF2019-07198 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 04/25/2024 From: James Zappone jimz@zapponemotors.com Subject: FW: CONSULTING AND WARRANTY INVOICE Date: March 19, 2018 at 12:13 PM To: Courtney Fredette ofredette@zapponemotors.com -----Original Message----- From: estaring@nycap.rr.com [mailto:estaring@nycap.rr.com] Sent: Sunday, March 18, 2018 11:03 PM To: James Zappone Cc: Matthew Zappone Subject: CONSULTING AND WARRANTY INVOICE Jim, Please let me know you have received these invoices, as well as the address change on invoices. Thank you, Eric JMR Excelerated Enterprises, LLC INVOICE DATE: 3/18/2018 INVOICE # 2061 8 Remington Road Customer ID Z25 Guilderland, NY 12303 518457-3997 BILL TO: ZAPPONE CJDR 1780 ROUTE 9 CLIFTON PARK, NY 12065 518-383-2277 [5elvice Fee] WARRANTY ADMINISTRATION@ $1,50D.00 PER WEEK WEEK 03/19 - 03/24/2018 1,50D.00 SUBTOTAL $ 1,50D.00 OTHER CONNENTS TAX RATE 0.0D0% 1. Total payment due upon receipt TAX $ - 2. Please include the invoice number on your check OTFIER $ - TOTAL $ 1,5D0.00 Make all checks payable to takQFremiacatma Fatacn I I FILED: FULTON COUNTY CLERK 04/25/2024 10:36 AM INDEX NO. EF2019-07198 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 04/25/2024 If you have any questions about this invoice, please contact Eric G.5taring Thank You For Your Business! 2038Wrtex42 LLC trauke Ternplatesby Wrtex42.ccrn Zappone CJDR Invoice...G.xisx FILED: FULTON COUNTY CLERK 04/25/2024 10:36 AM INDEX NO. EF2019-07198 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 04/25/2024 James Zappone From: estaring@nycap.rr.com Sent: Sunday, March 18, 2018 11:03 PM To: James Zappone Cc: Matthew Zappone Subject: CONSULTING AND WARRANTY INVOICE Attachments: Zappone CJDR Invoice Mar, 18 2018 Warranty.pdf; Zappone CJDR Invoice Mar, 18 2018 CONSULTING.xisx Jim, Please let me know you have received these invoices, as well as the address change on invoices. Thank you, Eric 1 FILED: FULTON COUNTY CLERK 04/25/2024 10:36 AM INDEX NO. EF2019-07198 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 04/25/2024 JMR Excelerated Enterprises, LLC INVOICE DATE: 3/18/2018 INVOICE # 2061 8 Remington Road Customer ID Z25 Guilderland, NY 12303 518-857-3997 BILL TO: ZAPPONE CJDR 1780 ROUTE 9 CLIFTON PARK, NY 12065 518-383-2277 [Service Fee] WARRANTY ADMINISTRATION @ $1,500.00 PER WEEK WEEK 03/19 - 03/24/2018 1,500.00 SUBTOTAL $ 1,500.00 OTHER COMMENTS TAX RATE 0.000% 1. Total payment due upon receipt TAX - $ 2. Please include the invoice number on your check OTHER - $ TOTAL $ 1,500.00 Make all checks payable to JMR Excelerated Enterp, LLC If you have any questions about this invoice, please contact Eric G.Staring Thank You For Your Business! © 2008 Vertex42 LLC Invoice Templates by Vertex42.com FILED: FULTON COUNTY CLERK 04/25/2024 10:36 AM INDEX NO. EF2019-07198 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 04/25/2024 JMR Excelerated Enterprises, LLC INVOICE DATE: 3/18/2018 INVOICE # 2062 8 Remington Road Customer ID Z25 Guilderland, NY 12303 518-857-3997 BILL TO: ZAPPONE CJDR 1780 ROUTE 9 CLIFTON PARK, NY 12065 518-383-2277 [Service Fee] CONSULTING @ $1,000 PER day,Value deal at $2,500 for 3 days 03/15,16,17/2018 ERIC 2,500.00 SUBTOTAL $ 2,500.00 OTHER COMMENTS TAX RATE 0.000% 1. Total payment due upon receipt TAX - $ OTHER - 2. Please include the invoice number on your check $ TOTAL $ 2,500.00 Make all checks payable to JMR Excelerated Enterp, LLC If you have any questions about this invoice, please contact Eric G.Staring Thank You For Your Business! © 2008 Vertex42 LLC Invoice Templates by Vertex42.com FILED: FULTON COUNTY CLERK 04/25/2024 10:36 AM INDEX NO. EF2019-07198 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 04/25/2024 James Za. "one From: estaring@nycap.rr.com Sent: Wednesday, August 8, 2018 2:27 AM To: James Zappone Subject: WARRANTY & CONSULTING INVOICES Attachments: Zappone CJDR Invoice Aug, 08 2018 CONSULTING.xisx; Zappone CJDR Invoice Aug., 08 2018 Warranty.pdf Jim, Please let me know you received these invoices. Thank you, Eric 1 FILED: FULTON COUNTY CLERK 04/25/2024 10:36 AM INDEX NO. EF2019-07198 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 04/25/2024 JMR Excelerated Enterprises, LLC INVOICE DATE: 8/8/2018 INVOICE # 2252 8 Remmington Road Customer ID Z25 Guilderland, NY 12303 518-857-3997 BILL TO: ZAPPONE CJDR 1780 ROUTE 9 CLIFTON PARK, NY 12065 518-383-2277 [Service Fee] CONSULTING @ $1,000 PER day, $3,500 for 5 days 07/31, 08/01,02,03 & 04/2018 ERIC 3,500.00 08/02/2018 DAWN 1,000.00 SUBTOTAL $ 4,500.00 OTHER COMMENTS TAX RATE 0.000% 1. Total payment due upon receipt TAX - $ OTHER - 2. Please include the invoice number on your check $ TOTAL $ 4,500.00 Make att checks payable to JMR Excelerated Enterp, LLC If you have any questions about this invoice, please contact Eric G.Staring Thank You For Your Business! © 2008 Vertex42 LLC Invoice Temptates by Vertex42.com FILED: FULTON COUNTY CLERK 04/25/2024 10:36 AM INDEX NO. EF2019-07198 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 04/25/2024 JMR Excelerated Enterprises, LLC INVOICE DATE: 8/8/2018 INVOICE # 2251 8 Remmington Road Customer ID Z25 Guilderland, NY 12303 518-857-3997 BILL TO: ZAPPONE CJDR 1780 ROUTE 9 CLIFTON PARK, NY 12065 518-383-2277 [Service Fee] WARRANTY ADMINISTRATION @ $1,500.00 PER WEEK WEEK 08/06 - 11/2018 1,500.00 SUBTOTAL $ 1,500.00 OTHER COMMENTS TAX RATE 0.000% 1. Total payment due upon receipt TAX - $ 2. Please include the number on your check OTHER - invoice $ TOTAL $ 1,500.00 Make all checks payable to JMR Excelerated Enterp, LLC If you have any questions about this invoice, please contact Eric G.Staring Thank You For Your Business! o 2008 Vertex42 LLC Invoice Templates by Vertex42.com FILED: FULTON COUNTY CLERK 04/25/2024 10:36 AM INDEX NO. EF2019-07198 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 04/25/2024 From: James Zappone jimz@zapponemotors.com Subject: FW: CONSULTING AND WARRANTY INVOICE Date: April 5, 2018 at 4:37 PM To: Kenneth Pelcher kpelcher@zapponemotors.com Can we pay this -----Original Message----- From: estaring@nycap.rr.com [mailto:estaring@nycap.rr.com] Sent: Wednesday, April 4, 2018 10:53 PM To: James Zappone Subject: CONSULTING AND WARRANTY INVOICE Jim, Hope you enjoyed your vacation in Florida. When you are back in the store I will update you in relation to process put in place and changes made at the dealership. Please let me know you have received these invoices. Eric JMR Excelerated Enterprises, LLC INVOICE DATE: 4/4/2018 INVOICE # 20B2 8 Remington Road Customer ID Z25 Guilderland, NY 12303 518457-3997 BILL TO: 1780 ROUTE 9 CLIFTON PARK, NY 12065 518-383-2277 [5ervice Fee] CONSULTING @ $1,000 PER day, Great Value @ $2,500 for 3 days 04/28,29, 30/2018 ERIC 2,500.0D SUBTOTAL $ 2,50D.00 T EdiñiE TAX RATE 0.000% 1. Total paymentdue upon receipt TAX $ 2. Please include the irwoice numberon your check OTHER $ TOTAL $ 2,500.00 Make all checks payable to um swarmea+ma en+men : t o FILED: FULTON COUNTY CLERK 04/25/2024 10:36 AM INDEX NO. EF2019-07198 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 04/25/2024 If you have any questions about this invoice, please contact Eric G.5taring Thank You For Your Business! © 2008Wrtex42 tLC Irwoke Ternpates ty Vertex42.corn JMR Exceterated Enterprises, LLC INVOICE DATE: 4/4/2018 INVOICE # 2081 8 Rernington Road Customer ID Z25 Guilderland, NY 12303 518457-3997 BILL TO: ZAPPONE CJDR 1780 ROUTE 9 CLIFTON PARK, NY 12065 518-383-2277 [5ervice Fee] WARRANTY ADMINISTRATION @ $1,500.0D PER WEEK WEEK 04/02 -07/2018 1,500.00 SUBTOTAL $ 1,500.00 OTHER COMMENTS TAX RATE 0.0D0% 1. Total payrnentdue upon receipt TAX $ 2. Please include the invoice nurnber on your check OTHER $ TOTAL $ 1,500.00 Make all checks payable to JMR Excelerated Enterp, LLC If you have any questions about this invoice, please contact Eric G.5taring FILED: FULTON COUNTY CLERK 04/25/2024 10:36 AM INDEX NO. EF2019-07198 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 04/25/2024 Thank You For Your Business! 2038Vertex42LLC twoice Ternøates by Verta42.ccen FILED: FULTON COUNTY CLERK 04/25/2024 10:36 AM INDEX NO. EF2019-07198 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 04/25/2024 From: James Zappone jimz@zapponemotors.com Subject: Fwd: CONSULTING AND WARRANTY INVOICE Date: April 11, 2018 at 5:11 PM To: Courtney Fredette cfredette@zapponemotors.com Sent from my iPhone Jim Zappone Zappone Chrysler Jeep Dodge Ram Clifton Park/ Granville Begin forwarded message: From: James Zappone . - Date: April 10, 2018 at 8:30:42 AM EDT "cthompson@zapponemotors.com" To: Subject: Fwd: CONSULTING AND WARRANTY INVOICE Invoices for the service people Sent from my iPhone Jim Zappone Zappone Chrysler Jeep Dodge Ram Clifton Park/ Granville Begin forwarded message: From: Date: April 10, 2018 at 8:17:04 AM EDT To: "JimZ@zapponemotors.com" Cc: Matthew Zappone <ñgap_pone@zap_ponemotors.com> Subject: CONSULTING AND WARRANTY INVOICE Jim, Please let me know you received these invoices. I was in the store 4 days last week as reflected billing. Thank you, Eric JMR Excelerated Enterprises, LLC INVOICE DATE: 4/10/2018 INVOICE # 2091 8 Remington Road Customer ID Z25 Guilderland, NY 12303 518-857-3997 BILL TO: ZAPPONE CJDR 1780 ROUTE 9 CLIFTON PARK, NY 12065 518-383-2277 [Service Fee] WARRANTY ADMINETRATION@ $1,500.0D PER WEEK FILED: FULTON COUNTY CLERK 04/25/2024 10:36 AM INDEX NO. EF2019-07198 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 04/25/2024 SUBTOTAL $ 1,500.00 ÖxHEREO GäÊ M M M $ TAX RATE 0.000% 1. Totat payment due upon receipt TAX $ - 2. Please include the invoice number on your check OTHER $ - TOTAL $ 1,500.00 Make all checks payable to JMR Excelerated Enterp, LLC If you have any questions about this invoice, please contact Eric G.5taring Thank You For Your Business! O 2038Vertex42LLC twoke Teniptatesby Vertex42.ccrn JMR Exceterated Enterprises, LLC INVOICE DATE: 4/10/2018 INVOICE # 2092 8 Remington Road Customer ID Z25 Guilderland, NY 12303 518-857-3997 BILL TO: ZAPPONE CJDR 1780 ROUTE 9 CLIFTON PARK, NY 12065 518-383-2277 [5enice Fee] CONSULTING @ $1,000 PER day, Great Value @ $3,000 for 4 days 04/04, 05, 06, & 07/ 2018 ERIC 3,000.0D FILED: FULTON COUNTY CLERK 04/25/2024 10:36 AM INDEX NO. EF2019-07198 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 04/25/2024 SUBTOTAL $ 3,00D.00 ØxHÊX On Ñ TAX RATE 0.000% 1. Total paymentdue upon receipt TAX $ 2. Please include the invoice number on your check OTHER $ TOTAL $ 3,000,00 Make att checks payable to JMR Excelerated Enterp, LLC if you have any questions about this invoice, please contact Eric G.5taring Thank Ya For YSr Business! © 2(08 Vertend2LLC kraice Ternpates try Vertes.42.ccrn FILED: FULTON COUNTY CLERK 04/25/2024 10:36 AM INDEX NO. EF2019-07198 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 04/25/2024 From: James Zappone jimz@zapponemotors.com Subject: Fwd: WARRANTY & CONSULTING INVOICES Date: April 16, 2018 at 10:13 AM To: Courtney Fredette cfredette@zapponemotors.com Begin forwarded message: From: Subject: WARRANTY & CONSULTING INVOICES Date: April 16, 2018 at 10:04:53 AM EDT To: "JimZ@zapponemotors.com" Cc: Matthew Zappone Jim, Please let me know you received these invoices. Let me know if you have a problem opening the invoices, I have new software. Thank you, Eric JMR Exceterated Enterprises, LLC INVOICE DATE: 4/16/2018 INVOICE # 2102 8 Remington Road Customer ID Z25 Guilderland, NY 12303 518457.3997 ZAPPONECJDR 1780 ROUTE 9 CLIFTON PARK, NY 12065 518 -383-22T1 [5ervice Fee] CONSULTING @ $1,000 PER day, Vatue Package @ $3,0DD for 4 days 04/ 11, 12, 13, lit 14/ 2018 ERIC 3,000.00 SUBT0rAL $ 3,00D.00 OTHER COMMENTS TAX RATE 0.000% 1. Total payment due upon receipt TAX $ - 2. Please include the invoice number on your check 01NER $ - TOTAL S 3,000.00 FILED: FULTON COUNTY CLERK 04/25/2024 10:36 AM INDEX NO. EF2019-07198 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 04/25/2024 Make att checks payable to JMR Excelerated Enterp, LLC If you have any questions about this invoice, please contact Eric G.5taring Thank You For Your Business! © 200BWrtex42 LLC ty.uke Ternptatesby Wrte£42.ccen JMR Exceterated Enterprises, LLC INVOICE DATE: 4/16/2018 INVOICE # 2101 8 Remington Road Customer ID Z25 Guilderland, NY 12303 518457-3997 BILL TO ZAPPONECJDR 1780 ROUTE 9 CLIFTON PARK, NY 12065 518-383-2277 [5ervice Fee] WARRANTY ADMINISTRATION @ $1,500.0D PER WEEK WEEK 04/16 - 21/2018 1,50D.00 SUBTOTAL 1,50D.0D OTHER COMMENTS TAX RATE 0.000% 1. Total payment due upon receipt TAX $ 2. Please include the invoice number on your check OTHER $ TOTAL $ 1,500.00 Make att checks payable to . . . . JMR Excelerated Enterp, LLC FILED: FULTON COUNTY CLERK 04/25/2024 10:36 AM INDEX NO. EF2019-07198 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 04/25/2024 If you have any questions about this invoice, please contact Eric G.Staring Thank You For Your Business! 208 Vertex42LLC knoke Ternpates ty Vertex42.ccen FILED: FULTON COUNTY CLERK 04/25/2024 10:36 AM INDEX NO. EF2019-07198 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 04/25/2024 From: James Zappone jimz@zapponemotors.com Subject: Fwd: WARRANTY & CONSULTING INVOICES ... - Date: May 22, 2018 at 8:15 PM To: Courtney Fredette cfredette@zapponemotors.com Court Eric's bill I'll print in am James Zappone Zappone Chrysler Jeep Dodge Clifton Park/ Granville Begin forwarded message: From: __ Date: May 22, 2018 at 6:48:31 PM EDT "JimZ@zapponemotors.com" To: Cc: Matthew Zappone Subject: WARRANTY & CONSULTING INVOICES Jim, Please let me know you received these invoices. Thank you, Eric JMR Exceterated Enterprises, LLC INVOICE DATE: 5/22/2018 INVOICE # 2151 8 Remmington Road Customer ID 225 Guilderland, NY 12303 518457-3997 BILL TO: ZAPPONECJDR 1780 ROUTE 9 CLIFTON PARK, NY 12065 518-383-2277 [5ervice Fee] WARRANTY ADMINISTRATION @ $1,500.00 PER WEEK WEEK 05/21 - 26/2018 1,500.00 SUBTOTAL $ 1,50D.00 OTHER CONNENTS TAX RATE 0.000% FILED: FULTON COUNTY CLERK 04/25/2024 10:36 AM INDEX NO. EF2019-07198 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 04/25/2024 2. Please include the invoice nurnber on your check OTHER $ TOTAL $ 1,500.00 Make all checks payable to JMR Excelerated Enterp, LLC