Preview
FILED: NASSAU COUNTY CLERK 05/16/2024 04:28 PM INDEX NO. 608592/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/16/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
--------------------------------------------------------------X
CEDAR COMMUNITIES AT MULBERRY GROVE, Index No.:
LLC
SUMMONS WITH NOTICE
Plaintiffs,
Plaintiff’s designate Nassau
-against- County as the place of trial.
BRANDON NORRIS,
Defendant.
--------------------------------------------------------------X
TO THE ABOVE NAMED DEFENDANTS:
PLEASE TAKE NOTICE THAT YOU ARE HEREBY SUMMONED to appear in this
action by serving a notice of appearance on the plaintiff(s) at the address set forth below, and to
do so within 20 days after the service of this Summons (not counting the day of service itself), or
within 30 days after service is complete if the summons is not delivered personally to you within
the State of New York.
Venue is proper in this Court pursuant to CPLR § 503(c) based on Plaintiff’s principal
office being in Nassau County, New York.
As set forth in Attachment A, this is an action for permanent injunctive relief, tortious
interference with contracts, tortious interference with business relationships, defamation, slander,
and libel.
Plaintiff seeks relief, including: (a) permanent injunctive relief; (b) compensatory
damages in an amount to be determined at trial; (c) attorneys’ fees and costs; and (d) such other
and further relief as the Court may deem just and proper.
YOU ARE HEREBY NOTIFIED that, on your failure to appear or answer, a
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FILED: NASSAU COUNTY CLERK 05/16/2024 04:28 PM INDEX NO. 608592/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/16/2024
judgment will be entered against you by default granting the relief requested above, including
damages of not less than $250,000 and additional amounts to be determined, plus interest at the
rate prescribed by law, attorneys’ fees, and costs of this action.
Dated: May _16_,
16 , 2024
New York, NY
Attorney for Plaintiffs
By:________________________________
Nicholas T. Terzulli, Esq.
Davidoff, Hutcher & Citron LLP
605 Third Ave, 34th Floor
New York, NY 10158
Phone: (212) 557-7200
Email: ntt@dhclegal.com
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FILED: NASSAU COUNTY CLERK 05/16/2024 04:28 PM INDEX NO. 608592/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/16/2024
ATTACHMENT A
NATURE OF ACTION
This is an action by plaintiff Cedar Communities at Mulberry Grove, LLC (“Plaintiff”)
against defendant Brandon Norris (“Defendant”).
On March 25, 2024, Plaintiff hired Defendant as a Maintenance Director to provide
maintenance services to residents of a senior living community (the “Community”).
On April 19, 2024, Plaintiff fired Defendant for insubordination, creating a negative work
environment, violation of company policy, and not completing tasks assigned by his direct
supervisor.
Following Defendant’s employment termination, and upon information and belief,
Defendant contacted residents of the Community and their family members and powers of attorney
advocating that these residents move out of the Community by making various untrue and
disparaging claims about the Community and Plaintiff. Defendant has bragged to Plaintiff in
writing about continuing to contact various parties with the sole intent of harming Plaintiff’s
business. Defendant clearly tortiously interfered with legally binding Agreements between the
Community and Community residents and continues to attempt to destroy the good name of
Plaintiff. This caused cause Plaintiff significant economic harm.
Additionally, upon hiring, Plaintiff executed a Confidentiality and Nondisclosure
Agreement (the “Nondisclosure Agreement”). Upon information and belief, the Plaintiff violated
numerous provisions of the Nondisclosure Agreement, including but are not limited to retaining
confidential information, using confidential information inappropriately following termination,
and specifically attempting to use said confidential information to damage the reputation of
Plaintiff.
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Plaintiff seeks relief in the form of an immediate and permanent injunction enjoining the
Defendant from contacting existing and potential Community residents and their family members,
guardians, and powers of attorney, and any and all of Plaintiff’s employees, managers, vendors,
contractors, service providers, and any other party regarding Plaintiff’s business. Plaintiff also
seeks compensatory damages to be determined by the Court along with attorneys’ fees and costs
and such other and further relief as the Court may deem just and proper.
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FILED: NASSAU COUNTY CLERK 05/16/2024 04:28 PM INDEX NO. 608592/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/16/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU Index No.:
CEDAR COMMUNITIES AT MULBERRY GROVE, LLC
Plaintiffs,
-against-
BRANDON NORRIS,
Defendant.
SUMMONS WITH NOTICE
Attorney for Plaintiff
Nicholas T. Terzulli, Esq.
Davidoff, Hutcher & Citron LLP
605 Third Ave, 34th Floor
New York, NY 10158
Phone: (212) 557-7200
Email: ntt@dhclegal.com
Certification under 22 NYCRR § 130-1.1-a
Attorney for Plaintiffs
By: ______________________
Nicholas T. Terzulli, Esq.
Davidoff, Hutcher & Citron LLP
605 Third Ave, 34th Floor
New York, NY 10158
Phone: (212) 557-7200
Email: ntt@dhclegal.com
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Preview
FILED: NASSAU COUNTY CLERK 05/16/2024 04:28 PM INDEX NO. 608592/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/16/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU --------------------------------------------------------------X CEDAR COMMUNITIES AT MULBERRY GROVE, Index No.: LLC SUMMONS WITH NOTICE Plaintiffs, Plaintiff’s designate Nassau -against- County as the place of trial. BRANDON NORRIS, Defendant. --------------------------------------------------------------X TO THE ABOVE NAMED DEFENDANTS: PLEASE TAKE NOTICE THAT YOU ARE HEREBY SUMMONED to appear in this action by serving a notice of appearance on the plaintiff(s) at the address set forth below, and to do so within 20 days after the service of this Summons (not counting the day of service itself), or within 30 days after service is complete if the summons is not delivered personally to you within the State of New York. Venue is proper in this Court pursuant to CPLR § 503(c) based on Plaintiff’s principal office being in Nassau County, New York. As set forth in Attachment A, this is an action for permanent injunctive relief, tortious interference with contracts, tortious interference with business relationships, defamation, slander, and libel. Plaintiff seeks relief, including: (a) permanent injunctive relief; (b) compensatory damages in an amount to be determined at trial; (c) attorneys’ fees and costs; and (d) such other and further relief as the Court may deem just and proper. YOU ARE HEREBY NOTIFIED that, on your failure to appear or answer, a 1 of 5 FILED: NASSAU COUNTY CLERK 05/16/2024 04:28 PM INDEX NO. 608592/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/16/2024 judgment will be entered against you by default granting the relief requested above, including damages of not less than $250,000 and additional amounts to be determined, plus interest at the rate prescribed by law, attorneys’ fees, and costs of this action. Dated: May _16_, 16 , 2024 New York, NY Attorney for Plaintiffs By:________________________________ Nicholas T. Terzulli, Esq. Davidoff, Hutcher & Citron LLP 605 Third Ave, 34th Floor New York, NY 10158 Phone: (212) 557-7200 Email: ntt@dhclegal.com 2 2 of 5 FILED: NASSAU COUNTY CLERK 05/16/2024 04:28 PM INDEX NO. 608592/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/16/2024 ATTACHMENT A NATURE OF ACTION This is an action by plaintiff Cedar Communities at Mulberry Grove, LLC (“Plaintiff”) against defendant Brandon Norris (“Defendant”). On March 25, 2024, Plaintiff hired Defendant as a Maintenance Director to provide maintenance services to residents of a senior living community (the “Community”). On April 19, 2024, Plaintiff fired Defendant for insubordination, creating a negative work environment, violation of company policy, and not completing tasks assigned by his direct supervisor. Following Defendant’s employment termination, and upon information and belief, Defendant contacted residents of the Community and their family members and powers of attorney advocating that these residents move out of the Community by making various untrue and disparaging claims about the Community and Plaintiff. Defendant has bragged to Plaintiff in writing about continuing to contact various parties with the sole intent of harming Plaintiff’s business. Defendant clearly tortiously interfered with legally binding Agreements between the Community and Community residents and continues to attempt to destroy the good name of Plaintiff. This caused cause Plaintiff significant economic harm. Additionally, upon hiring, Plaintiff executed a Confidentiality and Nondisclosure Agreement (the “Nondisclosure Agreement”). Upon information and belief, the Plaintiff violated numerous provisions of the Nondisclosure Agreement, including but are not limited to retaining confidential information, using confidential information inappropriately following termination, and specifically attempting to use said confidential information to damage the reputation of Plaintiff. 3 3 of 5 FILED: NASSAU COUNTY CLERK 05/16/2024 04:28 PM INDEX NO. 608592/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/16/2024 Plaintiff seeks relief in the form of an immediate and permanent injunction enjoining the Defendant from contacting existing and potential Community residents and their family members, guardians, and powers of attorney, and any and all of Plaintiff’s employees, managers, vendors, contractors, service providers, and any other party regarding Plaintiff’s business. Plaintiff also seeks compensatory damages to be determined by the Court along with attorneys’ fees and costs and such other and further relief as the Court may deem just and proper. 4 4 of 5 FILED: NASSAU COUNTY CLERK 05/16/2024 04:28 PM INDEX NO. 608592/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/16/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU Index No.: CEDAR COMMUNITIES AT MULBERRY GROVE, LLC Plaintiffs, -against- BRANDON NORRIS, Defendant. SUMMONS WITH NOTICE Attorney for Plaintiff Nicholas T. Terzulli, Esq. Davidoff, Hutcher & Citron LLP 605 Third Ave, 34th Floor New York, NY 10158 Phone: (212) 557-7200 Email: ntt@dhclegal.com Certification under 22 NYCRR § 130-1.1-a Attorney for Plaintiffs By: ______________________ Nicholas T. Terzulli, Esq. Davidoff, Hutcher & Citron LLP 605 Third Ave, 34th Floor New York, NY 10158 Phone: (212) 557-7200 Email: ntt@dhclegal.com 5 of 5