Preview
FILED: NASSAU COUNTY CLERK 11/09/2022 05:02 PM INDEX NO. 602826/2022
NYSCEF DOC. NO. 75 RECEIVED NYSCEF: 11/09/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
______________________________________________
BEN-ZION ALCALAY
Plaintiff, Index No.: 602826/2022
vs.
Motion Sequence No. 002
ATLAS CYBERSECURITY, LLC,
a New York Limited Liability Company and NOTICE OF MOTION
BARRY DYNKIN,
Defendants.
_______________________________________________/
PLEASE TAKE NOTICE that, upon the Memorandum of Law, dated November 10,
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 December 9, 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, plus interest from November 23, 2020, and for any further and different relief as this
Court deems just and proper.
PLEASE TAKE FURTHER NOTICE that, the return date on the instant motion, as set by
the Court, is December 9, 2022.
PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR 2214(b), and this Court’s
prior directive, you are required to serve copies of your answering papers (if any) on the
undersigned no later than December 1, 2022.
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 11/09/2022 05:02 PM INDEX NO. 602826/2022
NYSCEF DOC. NO. 75 RECEIVED NYSCEF: 11/09/2022
PLEASE TAKE FURTHER NOTICE that, pursuant to this Court’s directive, Plaintiff is
required to serve copies of his reply papers (if any) on Defendants’ counsel no later than December
8, 2022.
Dated: New York, New York
November 9, 2022
DAVIDOFF LAW FIRM, PLLC
By:
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
TO: all parties of record VIA NYSCEF and Mail to Gary Rosen Esq.:
ROSEN LAW LLC,
c/o GARY ROSEN ESQ.
counsel for Defendants, Atlas Cybersecurity, LLC and Barry Dynkin
216 Lakeville Road
Great Neck, New York 11020
(516) 437-3400
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 11/09/2022 05:02 PM INDEX NO. 602826/2022 NYSCEF DOC. NO. 75 RECEIVED NYSCEF: 11/09/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU ______________________________________________ BEN-ZION ALCALAY Plaintiff, Index No.: 602826/2022 vs. Motion Sequence No. 002 ATLAS CYBERSECURITY, LLC, a New York Limited Liability Company and NOTICE OF MOTION BARRY DYNKIN, Defendants. _______________________________________________/ PLEASE TAKE NOTICE that, upon the Memorandum of Law, dated November 10, 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 December 9, 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, plus interest from November 23, 2020, and for any further and different relief as this Court deems just and proper. PLEASE TAKE FURTHER NOTICE that, the return date on the instant motion, as set by the Court, is December 9, 2022. PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR 2214(b), and this Court’s prior directive, you are required to serve copies of your answering papers (if any) on the undersigned no later than December 1, 2022. 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 11/09/2022 05:02 PM INDEX NO. 602826/2022 NYSCEF DOC. NO. 75 RECEIVED NYSCEF: 11/09/2022 PLEASE TAKE FURTHER NOTICE that, pursuant to this Court’s directive, Plaintiff is required to serve copies of his reply papers (if any) on Defendants’ counsel no later than December 8, 2022. Dated: New York, New York November 9, 2022 DAVIDOFF LAW FIRM, PLLC By: 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 TO: all parties of record VIA NYSCEF and Mail to Gary Rosen Esq.: ROSEN LAW LLC, c/o GARY ROSEN ESQ. counsel for Defendants, Atlas Cybersecurity, LLC and Barry Dynkin 216 Lakeville Road Great Neck, New York 11020 (516) 437-3400 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