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FILED: NASSAU COUNTY CLERK 05/16/2022 01:51 PM INDEX NO. 602826/2022
NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 05/16/2022
SUPREME COURT STATE OF NEW YORK
COUNTY OF NASSAU
______________________________________________
BEN-ZION ALCALAY
Plaintiff, Index No.: 602826/2022
vs.
AMENDED NOTICE OF MOTION
ATLAS CYBERSECURITY, LLC,
a New York Limited Liability Company, and
BARRY DYNKIN,
Defendants.
_______________________________________________/
PLEASE TAKE NOTICE that, upon the Memorandum of Law, dated March 4, 2022, the
annexed attorney affirmation of Jonathan Marc Davidoff, Esq., the affidavit of Ben-Zion Alcalay,
and all exhibits annexed thereto, Plaintiff Ben-Zion Alcalay (“Plaintiff”), will move this Court, on
July 1, 2022, at 9:30 a.m., at 100 Supreme Court Drive, Mineola, New York 11501, or as soon
thereafter as counsel may be heard, for an Order, pursuant to CPLR §§ 3213 and 5406, to
domesticate and recover under the final judgement entered against Defendants, ATLAS
CYBERSECURITY, LLC and BARRY DYNKIN, on December 7, 2021, in the Circuit Court of
the 15th Judicial Circuit in and for Palm Beach County, State of Florida, in the amount of
$293,291.00, and for any further and different relief as this Court deems just and proper.
PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR 2214(b), you are required to
serve copies of your answering papers (if any) on the undersigned no later than seven days prior
to the date set forth above for the submission of this motion.
Page 1 of 2
DAVIDOFF LAW FIRM, PLLC
228 East 45th Street, Suite 1110, New York, New York 10017 ● Tel: (212) 587-5971 ● Fax (212) 658-9852
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FILED: NASSAU COUNTY CLERK 05/16/2022 01:51 PM INDEX NO. 602826/2022
NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 05/16/2022
Dated: New York, New York
May 16, 2022
DAVIDOFF LAW FIRM, PLLC
By: /JMD/
Jonathan Marc Davidoff, Esq.
Danielle Shayne Shapero, Esq.
Attorneys for Plaintiff
228 East 45th Street, Suite 1110
New York, New York 10017
Tel: 212-587-5971
Email: Jonathan@DavidoffLawFirm.com
Email: Danielle@DavidoffLawFirm.com
Page 2 of 2
DAVIDOFF LAW FIRM, PLLC
228 East 45th Street, Suite 1110, New York, New York 10017 ● Tel: (212) 587-5971 ● Fax (212) 658-9852
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Preview
FILED: NASSAU COUNTY CLERK 05/16/2022 01:51 PM INDEX NO. 602826/2022 NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 05/16/2022 SUPREME COURT STATE OF NEW YORK COUNTY OF NASSAU ______________________________________________ BEN-ZION ALCALAY Plaintiff, Index No.: 602826/2022 vs. AMENDED NOTICE OF MOTION ATLAS CYBERSECURITY, LLC, a New York Limited Liability Company, and BARRY DYNKIN, Defendants. _______________________________________________/ PLEASE TAKE NOTICE that, upon the Memorandum of Law, dated March 4, 2022, the annexed attorney affirmation of Jonathan Marc Davidoff, Esq., the affidavit of Ben-Zion Alcalay, and all exhibits annexed thereto, Plaintiff Ben-Zion Alcalay (“Plaintiff”), will move this Court, on July 1, 2022, at 9:30 a.m., at 100 Supreme Court Drive, Mineola, New York 11501, or as soon thereafter as counsel may be heard, for an Order, pursuant to CPLR §§ 3213 and 5406, to domesticate and recover under the final judgement entered against Defendants, ATLAS CYBERSECURITY, LLC and BARRY DYNKIN, on December 7, 2021, in the Circuit Court of the 15th Judicial Circuit in and for Palm Beach County, State of Florida, in the amount of $293,291.00, and for any further and different relief as this Court deems just and proper. PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR 2214(b), you are required to serve copies of your answering papers (if any) on the undersigned no later than seven days prior to the date set forth above for the submission of this motion. Page 1 of 2 DAVIDOFF LAW FIRM, PLLC 228 East 45th Street, Suite 1110, New York, New York 10017 ● Tel: (212) 587-5971 ● Fax (212) 658-9852 1 of 2 FILED: NASSAU COUNTY CLERK 05/16/2022 01:51 PM INDEX NO. 602826/2022 NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 05/16/2022 Dated: New York, New York May 16, 2022 DAVIDOFF LAW FIRM, PLLC By: /JMD/ Jonathan Marc Davidoff, Esq. Danielle Shayne Shapero, Esq. Attorneys for Plaintiff 228 East 45th Street, Suite 1110 New York, New York 10017 Tel: 212-587-5971 Email: Jonathan@DavidoffLawFirm.com Email: Danielle@DavidoffLawFirm.com Page 2 of 2 DAVIDOFF LAW FIRM, PLLC 228 East 45th Street, Suite 1110, New York, New York 10017 ● Tel: (212) 587-5971 ● Fax (212) 658-9852 2 of 2