On March 07, 2022 a
Motion,Ex Parte
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 08/07/2022 09:20 PM INDEX NO. 506569/2022
NYSCEF DOC. NO. 79 RECEIVED NYSCEF: 08/08/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS Index No.: 506569/2022
_______..___________________________________.._______________Ç
Jun Yan Guan, Individually and Derivatively on Behalf of
Angel Gift Nail Spa Inc., Angel Gift Nail Spa II Inc., NOTICE OF MOTION
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. MOT. SEQ. 004
Plaintiffs,
-against-
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.;
Defendants.
________________________________________Ç
PLEASE TAKE NOTICE that upon the annexed affirmation of Alfredo Tapia, Esq.
affirmed on August 6, 2022, together with all the exhibits annexed thereto, and upon the pleading
and proceedings heretofore had herein, the Plaintiffs, by their attorneys, THE TAPIA LAW
FIRM, PLLC, will move before the Supreme Court at the Courthouse located 360 Adams Street,
Brooklyn, NY, at an IAS Part 12, on the 20th day of October, 2022, at 9:30 A.M. in the forenoon
of that day, or as soon thereafter as counsel may be heard for an ORDER:
1. Consolidating this plenary action with the special proceedings under Index No. 509214/2022,
captioned as In the Matter of the Application of SUSAN HUA CHEN, as a 50% Shareholder
of At Angel Gift Nail Spa III Inc., a domestic Corporation vs. JUN YAN GUAN a/k/a
JAMES GUAN, as a 50% Shareholder of At Angel Gift Nail Spa III Inc., For Judicial
Dissolution of At Angel Gift Nail Spa III Inc. pursuant to Section 1104(a) of The Business
Corporation Law
2. Together with such other and further relief as this Court may deem just and paper.
PLEASE TAKE FURTHER NOTICE, that responding papers, if any, are to be served
upon the undersigned pursuant to CPLR 2214(b) at least seven (7) days before the retum date of
this motion.
1 of 2
FILED: KINGS COUNTY CLERK 08/07/2022 09:20 PM INDEX NO. 506569/2022
NYSCEF DOC. NO. 79 RECEIVED NYSCEF: 08/08/2022
Dated: August 7, 2022
Brooklyn, New York
Alfredo Tapia, Esq.
THE TAPIA LAW FIRM, PLLC
Attorneys for Plaintiffs
3456 Fulton Street,
TO: Brooklyn, New York 11208
T: 347-531-3664
Email: Atapia@thetapialawfirm.com
2 of 2
Document Filed Date
August 07, 2022
Case Filing Date
March 07, 2022
Category
Commercial Division
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Preview
FILED: KINGS COUNTY CLERK 08/07/2022 09:20 PM INDEX NO. 506569/2022 NYSCEF DOC. NO. 79 RECEIVED NYSCEF: 08/08/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS Index No.: 506569/2022 _______..___________________________________.._______________Ç Jun Yan Guan, Individually and Derivatively on Behalf of Angel Gift Nail Spa Inc., Angel Gift Nail Spa II Inc., NOTICE OF MOTION 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. MOT. SEQ. 004 Plaintiffs, -against- 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.; Defendants. ________________________________________Ç PLEASE TAKE NOTICE that upon the annexed affirmation of Alfredo Tapia, Esq. affirmed on August 6, 2022, together with all the exhibits annexed thereto, and upon the pleading and proceedings heretofore had herein, the Plaintiffs, by their attorneys, THE TAPIA LAW FIRM, PLLC, will move before the Supreme Court at the Courthouse located 360 Adams Street, Brooklyn, NY, at an IAS Part 12, on the 20th day of October, 2022, at 9:30 A.M. in the forenoon of that day, or as soon thereafter as counsel may be heard for an ORDER: 1. Consolidating this plenary action with the special proceedings under Index No. 509214/2022, captioned as In the Matter of the Application of SUSAN HUA CHEN, as a 50% Shareholder of At Angel Gift Nail Spa III Inc., a domestic Corporation vs. JUN YAN GUAN a/k/a JAMES GUAN, as a 50% Shareholder of At Angel Gift Nail Spa III Inc., For Judicial Dissolution of At Angel Gift Nail Spa III Inc. pursuant to Section 1104(a) of The Business Corporation Law 2. Together with such other and further relief as this Court may deem just and paper. PLEASE TAKE FURTHER NOTICE, that responding papers, if any, are to be served upon the undersigned pursuant to CPLR 2214(b) at least seven (7) days before the retum date of this motion. 1 of 2 FILED: KINGS COUNTY CLERK 08/07/2022 09:20 PM INDEX NO. 506569/2022 NYSCEF DOC. NO. 79 RECEIVED NYSCEF: 08/08/2022 Dated: August 7, 2022 Brooklyn, New York Alfredo Tapia, Esq. THE TAPIA LAW FIRM, PLLC Attorneys for Plaintiffs 3456 Fulton Street, TO: Brooklyn, New York 11208 T: 347-531-3664 Email: Atapia@thetapialawfirm.com 2 of 2