On May 15, 2024 a
Party Statement
was filed
involving a dispute between
Crater Candy Store Corp. D B A Crater Candy Corp. D B A Crater Candy,
Salah A. Abdulsamed, As Attorney-In-Fact For Abdullah Saleh Hasson,
and
Fatima Abdurado Saleh Al Grahomi,
Saleh A. Abdulsamed,
for Torts - Other (Fraud and Conversion)
in the District Court of Queens County.
Preview
INDEX NO. 710337/2024
(FILED: QUEENS COUNTY CLERK 05/16/2024 04:08 PM
NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 05/16/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
ee
SALAH A. ABDULSAMED, as attorney-in-fact for
ABDULLAH SALEH HASSON and CRATER EMERGENCY AFFIRMATION
CANDY STORE CORP. d/b/a CRATER CANDY
CORP. d/b/a CRATER CANDY Index No: 710337/2024
Plaintiffs,
-against-
SALEH A. ABDULSAMED and FATIMA ABDURADO
SALEH AL GRAHOMI
Defendants.
a
PAUL E. KERSON, an attorney admitted to practice before the Courts of this State, duly
affirms the following, pursuant to the penalties of perjury, pursuant to the penalties of CPLR
Rule 2106, and upon information and belief:
1 1 am a member of the Law Offices of Leavitt, Kerson & Sehati, Esqs. Together with my
colleague, Steven Simicich, Esq. of the Law Offices of Simicich & Limberis, Esqs., |
represent the Plaintiffs in connection with the above-named case.
2. This is a genuine legal emergency. My client, ABDULLAH SALEH HASSON is the
100% owner of his corporation and store, Co-Plaintiff CRATER CANDY STORE
CORP. d/b/a CRATER CANDY CORP. d/b/a CRATER CANDY. As he is now in his
native country of Yemen, he has appointed his attorney-in-fact SALAH A.
ABDULSAMED to act as Plaintiff for him.
The Defendants have locked Mr. Abdulsamed and Mr. Hasson out of their candy store
known as CRATERCANDY STORE CORP. d/b/a CRATER CANDY CORP. d/b/a
CRATER CANDY located at 30-23 30" Avenue, Astoria, Queens County, NY 11102.
Ot. 2
INDEX NO. 710337/2024
NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 05/16/2024
Defendants and Plaintiff have gotten into a fist fight at premises 30-23 30" Avenue in
Astoria, Queens County, NY 11102 over this matter. Police officers from the New York
City Police Department have been called. Arrests have been made.
Thus, this case cries out for an immediate stay pursuant to CPLR Section 2201
concerning the store at 30-23 30th Avenue, Astoria, Queens County, NY 11102 and the
two-family home where the proceeds of said store have been transferred located at 25-39
76th Street, East Elmhurst, NY 11370.
Further, a Preliminary Injunction pursuant to CPLR Article 63 is necessary so that
Plaintiffs can re-gain possession of their corporation and store and Defendants be
instructed to stay away from said corporate premises at 30-23 30th Avenue, Astoria,
Queens County, NY 11102.
Pursuant to 22 NYCRR 202.8-e I have sent notice of this application to the Defendants.
via Federal Express. A copy of my notification letter to these Defendants and the Federal
Express receipts are attached hereto as Exhibit J.
Except as indicated above, no prior application for this or similar relief has been requested
of this or any other Court.
WHEREFORE, | respectfully request that the instant application be granted in full.
fe ©
PAUL E. KERSON
=
Dated: May 16, 2024
Forest Hills, NY
2 of 2
Document Filed Date
May 16, 2024
Case Filing Date
May 15, 2024
Category
Torts - Other (Fraud and Conversion)
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
INDEX NO. 710337/2024 (FILED: QUEENS COUNTY CLERK 05/16/2024 04:08 PM NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 05/16/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS ee SALAH A. ABDULSAMED, as attorney-in-fact for ABDULLAH SALEH HASSON and CRATER EMERGENCY AFFIRMATION CANDY STORE CORP. d/b/a CRATER CANDY CORP. d/b/a CRATER CANDY Index No: 710337/2024 Plaintiffs, -against- SALEH A. ABDULSAMED and FATIMA ABDURADO SALEH AL GRAHOMI Defendants. a PAUL E. KERSON, an attorney admitted to practice before the Courts of this State, duly affirms the following, pursuant to the penalties of perjury, pursuant to the penalties of CPLR Rule 2106, and upon information and belief: 1 1 am a member of the Law Offices of Leavitt, Kerson & Sehati, Esqs. Together with my colleague, Steven Simicich, Esq. of the Law Offices of Simicich & Limberis, Esqs., | represent the Plaintiffs in connection with the above-named case. 2. This is a genuine legal emergency. My client, ABDULLAH SALEH HASSON is the 100% owner of his corporation and store, Co-Plaintiff CRATER CANDY STORE CORP. d/b/a CRATER CANDY CORP. d/b/a CRATER CANDY. As he is now in his native country of Yemen, he has appointed his attorney-in-fact SALAH A. ABDULSAMED to act as Plaintiff for him. The Defendants have locked Mr. Abdulsamed and Mr. Hasson out of their candy store known as CRATERCANDY STORE CORP. d/b/a CRATER CANDY CORP. d/b/a CRATER CANDY located at 30-23 30" Avenue, Astoria, Queens County, NY 11102. Ot. 2 INDEX NO. 710337/2024 NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 05/16/2024 Defendants and Plaintiff have gotten into a fist fight at premises 30-23 30" Avenue in Astoria, Queens County, NY 11102 over this matter. Police officers from the New York City Police Department have been called. Arrests have been made. Thus, this case cries out for an immediate stay pursuant to CPLR Section 2201 concerning the store at 30-23 30th Avenue, Astoria, Queens County, NY 11102 and the two-family home where the proceeds of said store have been transferred located at 25-39 76th Street, East Elmhurst, NY 11370. Further, a Preliminary Injunction pursuant to CPLR Article 63 is necessary so that Plaintiffs can re-gain possession of their corporation and store and Defendants be instructed to stay away from said corporate premises at 30-23 30th Avenue, Astoria, Queens County, NY 11102. Pursuant to 22 NYCRR 202.8-e I have sent notice of this application to the Defendants. via Federal Express. A copy of my notification letter to these Defendants and the Federal Express receipts are attached hereto as Exhibit J. Except as indicated above, no prior application for this or similar relief has been requested of this or any other Court. WHEREFORE, | respectfully request that the instant application be granted in full. fe © PAUL E. KERSON = Dated: May 16, 2024 Forest Hills, NY 2 of 2