On March 09, 2022 a
Exhibit,Appendix
was filed
involving a dispute between
Hybrid Advance,
and
Final Grade L.L.C. Dba Final Grade,
Martin Thomas Lumpp,
for Commercial - Contract
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 08/05/2022 03:35 PM INDEX NO. 506997/2022
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 09/16/2022
USHER LAW GROUP P.C.
Attorneys and Counselors at Law
Mikhail "" a 1022 Avenue Floor 2
Usher, Esq P,
"o*
Vladimir Nikhman, Esq Brooklyn, New York 11223
o*
Jason Valentin, Esq (t)(718) 484-7510
"*
Thomas Mirigliano, Esq (f)(718) 865-8566
Admitted in: "NY " NJ a FL Musheresq@gmail.com
(e)
Of Counsel *
August 30, 2022
VIA USPS CERTIFIED MAIL &
UPS 2 DAY
Martin Lumpp
Final Grade LLC
2360 River Rd
Petoskey, MI 49770
RE: Termination of Representation per Client Request
Dear Mr. Lumpp,
This letter confirms that in accordance with your request, this office will no longer be representing
you in connection with defense of FINAL GRADE L.L.C. DBA FINAL GRADE and MARTIN
LUMPP (506997/2022). In order for this firm to be relieved as counsel for you matter, please sign the
attached affidavit and return itto us as soon as possible in the postage paid envelope enclosed.
This office will be filing a MOTION TO WITHDRAW AS COUNSEL at the Kings County
Supreme Court located 360 Adams St, Brooklyn, NY 11201 on September 13, 2022.
PLEASE NOTE, the Corporate Defendants are required to be represented by an attorney
and cannot represent itselfpro se pursuant to New York CPLR 321.
Should you reconsider your request for this office to longer represent you in the matter,
please contact our office as soon as possible. If another attorney takes over the matter, please have
them contact us to obtain documents/pleadings previously filed by this office.
FILED: KINGS COUNTY CLERK 08/05/2022 03:35 PM INDEX NO. 506997/2022
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 09/16/2022
Thank you for your attention and cooperation in this matter. Should you have any questions,
please do not hesitate to contact our office at any time.
Respectfully yours,
/s/ Mikhail Usher
MIKHAIL USHER, ESQ.
Attorney at Law
FILED: KINGS COUNTY CLERK 08/05/2022 03:35 PM INDEX NO. 506997/2022
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 09/16/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
-------------------------------------------------------------------X Index No.: 506997/2022
HYBRID ADVANCE,
Plaintiff, AFFIDAVIT
vs.
FINAL GRADE L.L.C. DBA FINAL GRADE
And MARTIN LUMPP,
Defendants,
___-_________________________.._______..______________-___________x
I,Martin Lumpp, as a Defendant and agent of allcorporate Defendants in this matter do hereby
affirm the statement is true and correct to the best of knowledge and information.
following my
1. I am a Defendant in this Matter.
2. Usher Law Group P.C. was retained as attorneys for the instant matter, specifically Mikhail Usher,
Esq. to represent me in this matter.
3. While I know an appearance has been made by Usher Law Group on Defendant's behalf in this
matter, I have chosen to end my professional relationship with Usher Law Group P.C. And Mr. Usher
and I am currently seeking new counsel. As such I would ask that Mr. Usher and Usher Law Group
P.C. be permitted to withdraw from this matter as I no longer wish for him/them to represent my interests.
4. I have been advised by Mr. Usher that I should seek counsel for myself and that by New York law
the Corporate Defendant is required to be represented by an attorney and cannot represent itselfpro se
pursuant to New York CPLR 321.
5. Pursuant to the foregoing I ask that Mr. Usher's motion to withdraw from this matter be
granted without delay.
FILED: KINGS COUNTY CLERK 08/05/2022 03:35 PM INDEX NO. 506997/2022
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 09/16/2022
I,MARTIN LUMPP, as a Defendant and agent of all corporate Defendants in this matter,
swear and affirm that the foregoing statement is true and correct under the penalty of perjury.
MARTIN LUMPP
Sworn before me on this
day of , 2022
NOTARY PUBLIC
FILED: KINGS COUNTY CLERK 08/05/2022 03:35 PM INDEX NO. 506997/2022
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 09/16/2022
FIRST-CLASS
2
'
0 s
'talll'llill'l"IllltllullllPilillllll111111111rl4113llPl'
11223-2327
PC
2
GROUP
FL
P NY
AVENUE
LAW BROOKLYN
USHER
1022
49770-8866
LUMPP
LLCRD M1
RIVER
Grade PETOSKEY
MARTIN
Final2360
FILED: KINGS COUNTY CLERK 08/05/2022 03:35 PM INDEX NO. 506997/2022
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 09/16/2022
FIRST-CLASS
T5
us
pp.I.|.gpippi.a.ippi.||.I.hippl-pilipquiqhilill
11223-2327
PC
2
GROUP
FL
P NY
AVENUE
LAW BROOKLYN
USHER
1022
49770-8866
LUMPP
LLC RD MI
RIVER
Grade PETOSKEY
MARTIN
Final2360
FILED: KINGS COUNTY CLERK 08/05/2022 03:35 PM INDEX NO. 506997/2022
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 09/16/2022
$0.57
Ï 1
"Iligib"¹"rIlliiMi"ibili"il"illiill-MI-M¹"IIrllMil
11223-2327
PC
2
GROUP
FL
P NY
AVENUE
LAW BROOKLYN
USHER
1022
49770-8866
LUMPP
LLC RD MI
RIVER
Grade PETOSKEY
MARTIN
Final2360
FILED: KINGS COUNTY CLERK
. 08/05/2022 03:35 PM INDEX NO. 506997/2022
.
NYSCEF DOC. NO. 24 . RECEIVED NYSCEF: 09/16/2022
-
$0.579 11223
²°2²
G
gs,POS
FROM
^®!
II
"lalli"llilrleilkillmillvilil'IIIllililillist=Illililah
11223-2327
PC
2
GROUP
FL
P NY
AVENUE
LAW BROOKLYN
USHER
1022
49770-8866
LUMPP
LLC RD MI
RIVER
Grade PETOSKEY
MARTIN
Final2360
FILED: KINGS COUNTY CLERK 08/05/2022 03:35 PM INDEX NO. 506997/2022
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 09/16/2022
$6.579
USHER LAW GROUP PC
y
1022 AVENUE P FL 2
BROOKLYN NY 11223-2327
9414 8111 0803 3409 9590 32
lilullilutinflinlilmini.Ininlliullinlinlin I InI
MARTY LUMPP
2360 RIVER RD
PETOSKEY MI 49770-8866
POSAt SERVIC
STATES
UNITED
CERTIFIED MAIE
LABEL
FOR USE ONLY WITH (Mpb SHIPPING
Label 3800-N, January 2014 PSN7690-17-000-0906
FILED: KINGS COUNTY CLERK 08/05/2022 03:35 PM INDEX NO. 506997/2022
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 09/16/2022
$6.579
USHER LAW GROUP PC
asÎ-c
FL 2 1
1022 AVENUE P
BROOKLYN NY 11223-2327
a
8111 0803 3409 9539 00
9414
Inimilmlilminlilninllmilmilallml"lul
1,Infl
FINAL GRADE LLC
DBA FINAL GRADE
2360 RIVER RD
PETOSKEY MI 49770-8866
PCsrAtSeeviCE^
STATES
UNITCD
CERTIFIED MAlt
FOR USE ONLY WITH IMpb SHIPPING LABEL
I abel 1800 N. January 20I4 PSNrG9th1/ Onouno
FILED: KINGS COUNTY CLERK 08/05/2022 03:35 PM INDEX NO. 506997/2022
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 09/16/2022
1
OF
1
7-01
1LBS 3590
MI497 0499
497/0 AIR
02
4V8
DAY
MI
R29
GROUP,P.C. LUMPP
Y
FL RD
PETOSKEY 1Z
RIVER 2ND
N #:
BI)NG:3RD
Y TRACKING
U 2360
UPS
A
FILED: KINGS COUNTY CLERK 08/05/2022 03:35 PM INDEX NO. 506997/2022
NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 09/16/2022
OF1
1
7-01
2*
LBS 0604 OS
NVGESM
1 MI497
1604
497/0 AIR
02 20540
4V8
DAY
DE MI ×ot
R29
P.C.
ER
GROUP, S 2ND
1Z
#:
E 5 UPS
TRACKING
BILLi4G:
5
Document Filed Date
August 05, 2022
Case Filing Date
March 09, 2022
Category
Commercial - Contract
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Preview
FILED: KINGS COUNTY CLERK 08/05/2022 03:35 PM INDEX NO. 506997/2022 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 09/16/2022 USHER LAW GROUP P.C. Attorneys and Counselors at Law Mikhail "" a 1022 Avenue Floor 2 Usher, Esq P, "o* Vladimir Nikhman, Esq Brooklyn, New York 11223 o* Jason Valentin, Esq (t)(718) 484-7510 "* Thomas Mirigliano, Esq (f)(718) 865-8566 Admitted in: "NY " NJ a FL Musheresq@gmail.com (e) Of Counsel * August 30, 2022 VIA USPS CERTIFIED MAIL & UPS 2 DAY Martin Lumpp Final Grade LLC 2360 River Rd Petoskey, MI 49770 RE: Termination of Representation per Client Request Dear Mr. Lumpp, This letter confirms that in accordance with your request, this office will no longer be representing you in connection with defense of FINAL GRADE L.L.C. DBA FINAL GRADE and MARTIN LUMPP (506997/2022). In order for this firm to be relieved as counsel for you matter, please sign the attached affidavit and return itto us as soon as possible in the postage paid envelope enclosed. This office will be filing a MOTION TO WITHDRAW AS COUNSEL at the Kings County Supreme Court located 360 Adams St, Brooklyn, NY 11201 on September 13, 2022. PLEASE NOTE, the Corporate Defendants are required to be represented by an attorney and cannot represent itselfpro se pursuant to New York CPLR 321. Should you reconsider your request for this office to longer represent you in the matter, please contact our office as soon as possible. If another attorney takes over the matter, please have them contact us to obtain documents/pleadings previously filed by this office. FILED: KINGS COUNTY CLERK 08/05/2022 03:35 PM INDEX NO. 506997/2022 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 09/16/2022 Thank you for your attention and cooperation in this matter. Should you have any questions, please do not hesitate to contact our office at any time. Respectfully yours, /s/ Mikhail Usher MIKHAIL USHER, ESQ. Attorney at Law FILED: KINGS COUNTY CLERK 08/05/2022 03:35 PM INDEX NO. 506997/2022 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 09/16/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS -------------------------------------------------------------------X Index No.: 506997/2022 HYBRID ADVANCE, Plaintiff, AFFIDAVIT vs. FINAL GRADE L.L.C. DBA FINAL GRADE And MARTIN LUMPP, Defendants, ___-_________________________.._______..______________-___________x I,Martin Lumpp, as a Defendant and agent of allcorporate Defendants in this matter do hereby affirm the statement is true and correct to the best of knowledge and information. following my 1. I am a Defendant in this Matter. 2. Usher Law Group P.C. was retained as attorneys for the instant matter, specifically Mikhail Usher, Esq. to represent me in this matter. 3. While I know an appearance has been made by Usher Law Group on Defendant's behalf in this matter, I have chosen to end my professional relationship with Usher Law Group P.C. And Mr. Usher and I am currently seeking new counsel. As such I would ask that Mr. Usher and Usher Law Group P.C. be permitted to withdraw from this matter as I no longer wish for him/them to represent my interests. 4. I have been advised by Mr. Usher that I should seek counsel for myself and that by New York law the Corporate Defendant is required to be represented by an attorney and cannot represent itselfpro se pursuant to New York CPLR 321. 5. Pursuant to the foregoing I ask that Mr. Usher's motion to withdraw from this matter be granted without delay. FILED: KINGS COUNTY CLERK 08/05/2022 03:35 PM INDEX NO. 506997/2022 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 09/16/2022 I,MARTIN LUMPP, as a Defendant and agent of all corporate Defendants in this matter, swear and affirm that the foregoing statement is true and correct under the penalty of perjury. MARTIN LUMPP Sworn before me on this day of , 2022 NOTARY PUBLIC FILED: KINGS COUNTY CLERK 08/05/2022 03:35 PM INDEX NO. 506997/2022 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 09/16/2022 FIRST-CLASS 2 ' 0 s 'talll'llill'l"IllltllullllPilillllll111111111rl4113llPl' 11223-2327 PC 2 GROUP FL P NY AVENUE LAW BROOKLYN USHER 1022 49770-8866 LUMPP LLCRD M1 RIVER Grade PETOSKEY MARTIN Final2360 FILED: KINGS COUNTY CLERK 08/05/2022 03:35 PM INDEX NO. 506997/2022 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 09/16/2022 FIRST-CLASS T5 us pp.I.|.gpippi.a.ippi.||.I.hippl-pilipquiqhilill 11223-2327 PC 2 GROUP FL P NY AVENUE LAW BROOKLYN USHER 1022 49770-8866 LUMPP LLC RD MI RIVER Grade PETOSKEY MARTIN Final2360 FILED: KINGS COUNTY CLERK 08/05/2022 03:35 PM INDEX NO. 506997/2022 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 09/16/2022 $0.57 Ï 1 "Iligib"¹"rIlliiMi"ibili"il"illiill-MI-M¹"IIrllMil 11223-2327 PC 2 GROUP FL P NY AVENUE LAW BROOKLYN USHER 1022 49770-8866 LUMPP LLC RD MI RIVER Grade PETOSKEY MARTIN Final2360 FILED: KINGS COUNTY CLERK . 08/05/2022 03:35 PM INDEX NO. 506997/2022 . NYSCEF DOC. NO. 24 . RECEIVED NYSCEF: 09/16/2022 - $0.579 11223 ²°2² G gs,POS FROM ^®! II "lalli"llilrleilkillmillvilil'IIIllililillist=Illililah 11223-2327 PC 2 GROUP FL P NY AVENUE LAW BROOKLYN USHER 1022 49770-8866 LUMPP LLC RD MI RIVER Grade PETOSKEY MARTIN Final2360 FILED: KINGS COUNTY CLERK 08/05/2022 03:35 PM INDEX NO. 506997/2022 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 09/16/2022 $6.579 USHER LAW GROUP PC y 1022 AVENUE P FL 2 BROOKLYN NY 11223-2327 9414 8111 0803 3409 9590 32 lilullilutinflinlilmini.Ininlliullinlinlin I InI MARTY LUMPP 2360 RIVER RD PETOSKEY MI 49770-8866 POSAt SERVIC STATES UNITED CERTIFIED MAIE LABEL FOR USE ONLY WITH (Mpb SHIPPING Label 3800-N, January 2014 PSN7690-17-000-0906 FILED: KINGS COUNTY CLERK 08/05/2022 03:35 PM INDEX NO. 506997/2022 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 09/16/2022 $6.579 USHER LAW GROUP PC asÎ-c FL 2 1 1022 AVENUE P BROOKLYN NY 11223-2327 a 8111 0803 3409 9539 00 9414 Inimilmlilminlilninllmilmilallml"lul 1,Infl FINAL GRADE LLC DBA FINAL GRADE 2360 RIVER RD PETOSKEY MI 49770-8866 PCsrAtSeeviCE^ STATES UNITCD CERTIFIED MAlt FOR USE ONLY WITH IMpb SHIPPING LABEL I abel 1800 N. January 20I4 PSNrG9th1/ Onouno FILED: KINGS COUNTY CLERK 08/05/2022 03:35 PM INDEX NO. 506997/2022 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 09/16/2022 1 OF 1 7-01 1LBS 3590 MI497 0499 497/0 AIR 02 4V8 DAY MI R29 GROUP,P.C. LUMPP Y FL RD PETOSKEY 1Z RIVER 2ND N #: BI)NG:3RD Y TRACKING U 2360 UPS A FILED: KINGS COUNTY CLERK 08/05/2022 03:35 PM INDEX NO. 506997/2022 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 09/16/2022 OF1 1 7-01 2* LBS 0604 OS NVGESM 1 MI497 1604 497/0 AIR 02 20540 4V8 DAY DE MI ×ot R29 P.C. ER GROUP, S 2ND 1Z #: E 5 UPS TRACKING BILLi4G: 5