On March 07, 2022 a
DEMAND FOR: - Demand to Plaintiff to confirm date and removal of inventory
was filed
involving a dispute between
Angel City Nail Spa Inc,
Angel Gift Nail Spa Iii Inc,
Angel Gift Nail Spa Ii Inc,
Angel Gift Nail Spa Inc.,
Angel Gift Nail Spa Iv Inc,
At Angel City Nail Spa Inc.,
At Angel Gift Nail Spa Iii Inc.,
At Angel Gift Nail Spa Ii Inc.,
Jun Yan Guan,
and
Angel City Nail Spa Inc.,
Angel Gift Nail Spa Iii Inc,
Angel Gift Nail Spa Ii Inc,
Angel Gift Nail Spa Inc,
Angel Gift Nail Spa Iv Inc,
At Angel City Nail Spa Inc.,
At Angel Gift Nail Spa Iii Inc,
At Angel Gift Nail Spa Ii Inc,
Hua Chen,
Jianping Dai,
Metro City Bank,
Royal Business Bank,
Tao Lin,
Vincent Huang,
Vincent Huang Cpa Pc,
for Commercial Division
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 05/03/2022 05:08 PM INDEX NO. 506569/2022
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 05/03/2022
LAW OFFICES OF BING LI, LLC
ATTORNEYS AT LAW
1430 BROADWAY, SUITE 1802
NEW YORK, NY 10018-3308
TELEPHONE: (212) 967-7690
FACSIMILE: (212) 967-7852
NEW JERSEY OFFICE
44 SYLVAN AVENUE, SUITE 1F
ENGLEWOOD CLIFFS, NJ 07632-2417
TELEPHONE: (201) 585-8888
FACSIMILE: (201) 632-7000
BING LI † † MEMBER NY & NJ BARS
bli@blillc.com
May 2, 2022
VIA EFILE AND EMAIL (Atapia@thetapialawfirm.com)
Alfredo Tapia, Esq.
The Tapia Law Firm, PLLC
3456 Fulton Street
Brooklyn, NY 11208
Re: Jun Yan Guan v. Hua Chen a/k/a Susan Hua Chen,
Tao Lin, Jianping Dai, Angel Gift Nail Spa, Inc., Angel Gift
Nail Spa II Inc., Angel Gift Nail Spa III Inc., Angel Gift Nail
Spa IV Inc., At Angel Gift Nail Spa II Inc., At Angel Gift
Nail Spa III Inc., Angel City Nail Spa, Inc., At Angel City
Nail Spa, Inc., Vincent Huang, Vincent Huang CPA P.C.,
Royal Business Bank, Metro City Bank
Index No. 506569/2022
Related Action:
In the Matter of Susan Hua Chen for Judicial Dissolution
of At Angle Gift Nail Spa III, Inc.
Index No.: 509214/2022
Dear Mr. Tapia:
I am attorney of record for Hua Chen a/k/a Susan Hua Chen (“Chen”), Tao Lin
(“Lin”), Jianping Dai (“Dai”), At Angel Gift Nail Spa II Inc. (“At Angel II”), At Angel City
Nail Spa, Inc. (“At Angel City”), and the predecessors-in-interests of At Angel II and At
Angel City respectively in connection with the above-referenced action you commenced on
behalf of your client Jun Yan Guan (Index No. 506569/2022). As you are aware, I am also
attorney of record for Chen in connection with the above-referenced related action seeking
judicial dissolution of At Angel III (Index No. 509214/2022).
I write to inform you that on Tuesday, May 10, 2022, at 10:00 a.m., my client Chen
will remove the equipment and materials inside the store premises located at 8409 Fifth
Avenue, Brooklyn, for the purposes of vacating the premises and surrender same to the
Landlord.
1 of 3
FILED: KINGS COUNTY CLERK 05/03/2022 05:08 PM INDEX NO. 506569/2022
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 05/03/2022
Alfredo Tapia, Esq.
May 3, 2022
Page 2
I will be at the premises at the above-stated time to supervise the moving and record
the inventory to be moved out. I request that you be present so that you and I will jointly
supervise the event. If the above-stated time is not convenient to you, please let me know
another time good for you and we will reschedule.
The equipment and materials will be moved to a paid public storage to which you and
your client will have access upon your verification and acknowledgement and will be stored
there until otherwise ordered by the Court or by our respective clients’ consent. I have
contacted one located in Long Island City with a monthly storage charge of $335 and a one-
time registration fee of $29 to be paid upon reservation. Your client and mine should equally
be responsible for the monthly storage charges.
My client has informed me that the following equipment and property are inside the
store and will be removed to the public storage:
Item Quantity
Manicure desk (double) 4
Manicure desk (single) 1
Pedicure chair 9
Pedicure service stool 9
Tower heating box 2
Sanitizing machine 1
Nail oils, polish gel, and
other accessories to be counted (about a few hundred bottles)
Microwave machine 1
Refrigerator 1
Washing machine 1
Massage bed 3
Nail oil cabinets (7 drawers) 3
After the removal of the equipment and materials, my client will sign the Surrender of
Lease drafted by George Stavropoulos, Esq., the landlord’s attorney, and sent by Mr.
Stavropoulos to both of us on April 1, 2022. It is necessary that my client return the premises
to the landlord without any further delay. My client is a joint tenant with your client on the
underlying lease they signed in January 2011 and, as such, is personally liable with your client
to the landlord for the unpaid monthly rents. The store has remained closed to the public
since March 17, 2022 and, to my client’s information, the shareholders did not pay the
monthly rent of April or May. It is highly unlikely that the shareholders will not pay the
monthly rent for June and, as the Court has scheduled the judicial dissolution hearing for
June 30, 2022, it is also likely that they will not pay the monthly rent for July. My client did
not initially agree to the Surrender of Lease because it provides that “[a]ny property
remaining on the Premises after the date hereof shall be deemed abandoned.” Because my
client believes that the property remaining on the Premises still have significant resale value,
my client does not want to abandon it. By removing the equipment and materials from the
2 of 3
FILED: KINGS COUNTY CLERK 05/03/2022 05:08 PM INDEX NO. 506569/2022
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 05/03/2022
Alfredo Tapia, Esq.
May 3, 2022
Page 3
premises and then tender surrender to the Landlord, my client (and your client as well) will be
able to preserve the property and cease to be responsible for any future monthly rents.
Because of the mounting rental liability to my client (and to yours) and because of
limited availability of public storage space, I need to reserve the space as soon as possible.
Therefore, I request that you respond and confirm as to the date of moving as soon as you can
but no later than tomorrow, May 4, 2022. In the event you choose to ignore this request,
my client will proceed with the moving and surrender as planned.
Very truly yours,
/s/ Bing Li
Bing Li
cc: George Stavropoulos, Esq.
(via email gstavesq@aol.com)
Ms. Susan Hua Chen
3 of 3
Preview
FILED: KINGS COUNTY CLERK 05/03/2022 05:08 PM INDEX NO. 506569/2022 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 05/03/2022 LAW OFFICES OF BING LI, LLC ATTORNEYS AT LAW 1430 BROADWAY, SUITE 1802 NEW YORK, NY 10018-3308 TELEPHONE: (212) 967-7690 FACSIMILE: (212) 967-7852 NEW JERSEY OFFICE 44 SYLVAN AVENUE, SUITE 1F ENGLEWOOD CLIFFS, NJ 07632-2417 TELEPHONE: (201) 585-8888 FACSIMILE: (201) 632-7000 BING LI † † MEMBER NY & NJ BARS bli@blillc.com May 2, 2022 VIA EFILE AND EMAIL (Atapia@thetapialawfirm.com) Alfredo Tapia, Esq. The Tapia Law Firm, PLLC 3456 Fulton Street Brooklyn, NY 11208 Re: Jun Yan Guan v. Hua Chen a/k/a Susan Hua Chen, Tao Lin, Jianping Dai, Angel Gift Nail Spa, Inc., Angel Gift Nail Spa II Inc., Angel Gift Nail Spa III Inc., Angel Gift Nail Spa IV Inc., At Angel Gift Nail Spa II Inc., At Angel Gift Nail Spa III Inc., Angel City Nail Spa, Inc., At Angel City Nail Spa, Inc., Vincent Huang, Vincent Huang CPA P.C., Royal Business Bank, Metro City Bank Index No. 506569/2022 Related Action: In the Matter of Susan Hua Chen for Judicial Dissolution of At Angle Gift Nail Spa III, Inc. Index No.: 509214/2022 Dear Mr. Tapia: I am attorney of record for Hua Chen a/k/a Susan Hua Chen (“Chen”), Tao Lin (“Lin”), Jianping Dai (“Dai”), At Angel Gift Nail Spa II Inc. (“At Angel II”), At Angel City Nail Spa, Inc. (“At Angel City”), and the predecessors-in-interests of At Angel II and At Angel City respectively in connection with the above-referenced action you commenced on behalf of your client Jun Yan Guan (Index No. 506569/2022). As you are aware, I am also attorney of record for Chen in connection with the above-referenced related action seeking judicial dissolution of At Angel III (Index No. 509214/2022). I write to inform you that on Tuesday, May 10, 2022, at 10:00 a.m., my client Chen will remove the equipment and materials inside the store premises located at 8409 Fifth Avenue, Brooklyn, for the purposes of vacating the premises and surrender same to the Landlord. 1 of 3 FILED: KINGS COUNTY CLERK 05/03/2022 05:08 PM INDEX NO. 506569/2022 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 05/03/2022 Alfredo Tapia, Esq. May 3, 2022 Page 2 I will be at the premises at the above-stated time to supervise the moving and record the inventory to be moved out. I request that you be present so that you and I will jointly supervise the event. If the above-stated time is not convenient to you, please let me know another time good for you and we will reschedule. The equipment and materials will be moved to a paid public storage to which you and your client will have access upon your verification and acknowledgement and will be stored there until otherwise ordered by the Court or by our respective clients’ consent. I have contacted one located in Long Island City with a monthly storage charge of $335 and a one- time registration fee of $29 to be paid upon reservation. Your client and mine should equally be responsible for the monthly storage charges. My client has informed me that the following equipment and property are inside the store and will be removed to the public storage: Item Quantity Manicure desk (double) 4 Manicure desk (single) 1 Pedicure chair 9 Pedicure service stool 9 Tower heating box 2 Sanitizing machine 1 Nail oils, polish gel, and other accessories to be counted (about a few hundred bottles) Microwave machine 1 Refrigerator 1 Washing machine 1 Massage bed 3 Nail oil cabinets (7 drawers) 3 After the removal of the equipment and materials, my client will sign the Surrender of Lease drafted by George Stavropoulos, Esq., the landlord’s attorney, and sent by Mr. Stavropoulos to both of us on April 1, 2022. It is necessary that my client return the premises to the landlord without any further delay. My client is a joint tenant with your client on the underlying lease they signed in January 2011 and, as such, is personally liable with your client to the landlord for the unpaid monthly rents. The store has remained closed to the public since March 17, 2022 and, to my client’s information, the shareholders did not pay the monthly rent of April or May. It is highly unlikely that the shareholders will not pay the monthly rent for June and, as the Court has scheduled the judicial dissolution hearing for June 30, 2022, it is also likely that they will not pay the monthly rent for July. My client did not initially agree to the Surrender of Lease because it provides that “[a]ny property remaining on the Premises after the date hereof shall be deemed abandoned.” Because my client believes that the property remaining on the Premises still have significant resale value, my client does not want to abandon it. By removing the equipment and materials from the 2 of 3 FILED: KINGS COUNTY CLERK 05/03/2022 05:08 PM INDEX NO. 506569/2022 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 05/03/2022 Alfredo Tapia, Esq. May 3, 2022 Page 3 premises and then tender surrender to the Landlord, my client (and your client as well) will be able to preserve the property and cease to be responsible for any future monthly rents. Because of the mounting rental liability to my client (and to yours) and because of limited availability of public storage space, I need to reserve the space as soon as possible. Therefore, I request that you respond and confirm as to the date of moving as soon as you can but no later than tomorrow, May 4, 2022. In the event you choose to ignore this request, my client will proceed with the moving and surrender as planned. Very truly yours, /s/ Bing Li Bing Li cc: George Stavropoulos, Esq. (via email gstavesq@aol.com) Ms. Susan Hua Chen 3 of 3