Preview
FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019
NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021
EXHIBIT E
FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019
NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X
: Index No. 527036/2019
SHAUL KOPELOWITZ, :
: SUBPOENA DUCES TECUM
Plaintiff, :
:
- against - :
:
TOBY MOSKOWITZ and MICHAEL a/k/a YECHIEL :
LICHTENSTEIN, :
:
Defendants. :
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X
TO: 19 Kent Development LLC
Address: 199 Lee Avenue, #693
Brooklyn, New York 11211
GREETINGS:
WHEREAS, in an action in the Supreme Court of the State of New York, County of Kings,
between plaintiff SHAUL KOPELOWITZ (the “Judgment Creditor”), and defendants TOBY
MOSKOWITZ and MICHAEL a/k/a YECHIEL LICHTENSTEIN (the “Judgment Debtor(s)”), a
judgment was duly entered on December 16, 2019, in favor of the Judgment Creditor and against
the Judgment Debtors (the “Judgment”), in the sum of $6,350,225.00; and
WHEREAS, the witness has an office for the regular transaction of business in person in New
York County; and
WHEREAS, the judgment debtor’s last known addresses are as follows:
Toby Moskowitz
137-55 71st Ave.,
Flushing, New York 11367
Michael a/k/a Yechiel Lichtenstein
929 E 5th Street
Brooklyn, New York 11230
WE COMMAND YOU, pursuant to CPLR 5224, that all business and excuses being
laid aside, to produce and permit the party seeking discovery, or someone acting on his or her
behalf, to inspect, copy, test or photograph at the Law Office of Jeffrey Fleischmann PC,
FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019
NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021
attorneys for the Plaintiff herein, located at 150 Broadway, Suite 900, New York, New York
10038, on December 1, 2020 at 10:00 am and at any recessed or adjourned date, all documents
or any things which are in the possession, custody or control designated as follows:
All books, records and papers in your possession, custody or control relating to all funds
or accounts held, directly or indirectly, or in escrow, related to, by or on behalf of TOBY
MOSKOWITZ a/k/a TOBY MOSKOVITS and/or MICHAEL a/k/a YECHIEL
LICHTENSTEIN and any entities in which TOBY MOSKOWITZ a/k/a TOBY
MOSKOVITS and/or MICHAEL a/k/a YECHIEL LICHTENSTEIN have a direct or
indirect interest, including without limitation, GRAND LIVING LLC, 96 WYTHE
ACQUISITION LLC, 215 MOORE ST ACQUISITION LLC, 232 SEIGEN
ACQUISITION LLC, 564 ST. JOHNS LLC and 564 ST. JOHNS ACQUISITION LLC,
and copies of all proof of such funds, including account opening documents, tax documents, tax
returns, account closing documents, operating agreements, formation documents, authorized
signatories, deposits, wire transfers, funds held in escrow, escrow accounts, and account
statements to and from said accounts, including copies of the checks (front and back) and
deposit slips (front and back), and copies of all checks (front and back) written against, or
deposited in, said accounts or funds, and the names, telephone numbers, and addresses of all
authorized signatories on such accounts, from January 1, 2015 until the present date.
You may comply with the within subpoena duces tecum by having the requisite
documents and things produced by a person able to identify them and testify respecting their
origin, purpose and custody at the Law Office of Jeffrey Fleischmann PC on or before December
1, 2020. CPLR 2305(b).
2
FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019
NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021
PLEASE TAKE FURTHER NOTICE THAT, failure to comply with this Subpoena is
punishable as a contempt of court and shall make you liable to the person on whose behalf this
Subpoena was issued for a penalty not to exceed Fifty Dollars and all damages sustained by
reason of your failure to comply.
I HEREBY CERTIFY THAT THIS INFORMATION SUBPOENA COMPLIES WITH
RULE 5224 OF THE CIVIL PRACTICE LAW AND RULES AND THAT I HAVE A
REASONABLE BELIEF THAT THE PARTY RECEIVING THE SUBPOENA HAS IN THEIR
POSSESSION INFORMATION ABOUT THE DEBTOR THAT WILL ASSIST THE
CREDITOR IN COLLECTING THE JUDGMENT.
Dated: New York, New York
November 12, 2020
LAW OFFICE OF JEFFREY FLEISCHMANN PC
By: __________________________
Jeffrey Fleischmann, Esq.
Attorneys for Plaintiff Shaul Kopelowitz
150 Broadway, Suite 900
New York, New York 10038
Tel. (646) 657-9623
Fax (646) 351-0694
jf@lawjf.com
.
3
FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019
NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X
: Index No. 527036/2019
SHAUL KOPELOWITZ, :
: SUBPOENA DUCES TECUM
Plaintiff, :
:
- against - :
:
TOBY MOSKOWITZ and MICHAEL a/k/a YECHIEL :
LICHTENSTEIN, :
:
Defendants. :
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X
TO: 96 Wythe Acquisition LLC
Address: 1274 49th Street, #184
Brooklyn, New York 11219
GREETINGS:
WHEREAS, in an action in the Supreme Court of the State of New York, County of Kings,
between plaintiff SHAUL KOPELOWITZ (the “Judgment Creditor”), and defendants TOBY
MOSKOWITZ and MICHAEL a/k/a YECHIEL LICHTENSTEIN (the “Judgment Debtor(s)”), a
judgment was duly entered on December 16, 2019, in favor of the Judgment Creditor and against
the Judgment Debtors (the “Judgment”), in the sum of $6,350,225.00; and
WHEREAS, the witness has an office for the regular transaction of business in person in New
York County; and
WHEREAS, the judgment debtor’s last known addresses are as follows:
Toby Moskowitz
137-55 71st Ave.,
Flushing, New York 11367
Michael a/k/a Yechiel Lichtenstein
929 E 5th Street
Brooklyn, New York 11230
WE COMMAND YOU, pursuant to CPLR 5224, that all business and excuses being
laid aside, to produce and permit the party seeking discovery, or someone acting on his or her
behalf, to inspect, copy, test or photograph at the Law Office of Jeffrey Fleischmann PC,
FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019
NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021
attorneys for the Plaintiff herein, located at 150 Broadway, Suite 900, New York, New York
10038, on December 1, 2020 at 10:00 am and at any recessed or adjourned date, all documents
or any things which are in the possession, custody or control designated as follows:
All books, records and papers in your possession, custody or control relating to all funds
or accounts held, directly or indirectly, or in escrow, related to, by or on behalf of TOBY
MOSKOWITZ a/k/a TOBY MOSKOVITS and/or MICHAEL a/k/a YECHIEL
LICHTENSTEIN and any entities in which TOBY MOSKOWITZ a/k/a TOBY
MOSKOVITS and/or MICHAEL a/k/a YECHIEL LICHTENSTEIN have a direct or
indirect interest, including without limitation, GRAND LIVING LLC, 19 KENT
DEVELOPMENT LLC, 215 MOORE ST ACQUISITION LLC, 232 SEIGEN
ACQUISITION LLC, 564 ST. JOHNS LLC and 564 ST. JOHNS ACQUISITION LLC,
and copies of all proof of such funds, including account opening documents, tax documents, tax
returns, account closing documents, operating agreements, formation documents, authorized
signatories, deposits, wire transfers, funds held in escrow, escrow accounts, and account
statements to and from said accounts,, including copies of the checks (front and back) and
deposit slips (front and back), and copies of all checks (front and back) written against, or
deposited in, said accounts or funds, and the names, telephone numbers, and addresses of all
authorized signatories on such accounts, from January 1, 2015 until the present date.
You may comply with the within subpoena duces tecum by having the requisite
documents and things produced by a person able to identify them and testify respecting their
origin, purpose and custody at the Law Office of Jeffrey Fleischmann PC on or before December
1, 2020. CPLR 2305(b).
2
FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019
NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021
PLEASE TAKE FURTHER NOTICE THAT, failure to comply with this Subpoena is
punishable as a contempt of court and shall make you liable to the person on whose behalf this
Subpoena was issued for a penalty not to exceed Fifty Dollars and all damages sustained by
reason of your failure to comply.
I HEREBY CERTIFY THAT THIS INFORMATION SUBPOENA COMPLIES WITH
RULE 5224 OF THE CIVIL PRACTICE LAW AND RULES AND THAT I HAVE A
REASONABLE BELIEF THAT THE PARTY RECEIVING THE SUBPOENA HAS IN THEIR
POSSESSION INFORMATION ABOUT THE DEBTOR THAT WILL ASSIST THE
CREDITOR IN COLLECTING THE JUDGMENT.
Dated: New York, New York
November 12, 2020
LAW OFFICE OF JEFFREY FLEISCHMANN PC
By: __________________________
Jeffrey Fleischmann, Esq.
Attorneys for Plaintiff Shaul Kopelowitz
150 Broadway, Suite 900
New York, New York 10038
Tel. (646) 657-9623
Fax (646) 351-0694
jf@lawjf.com
.
3
FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019
NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X
: Index No. 527036/2019
SHAUL KOPELOWITZ, :
: SUBPOENA DUCES TECUM
Plaintiff, :
:
- against - :
:
TOBY MOSKOWITZ and MICHAEL a/k/a YECHIEL :
LICHTENSTEIN, :
:
Defendants. :
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X
TO: 215 Moore St Acquisition LLC
Address: 1274 49th Street, Ste 184
Brooklyn, New York 11219
GREETINGS:
WHEREAS, in an action in the Supreme Court of the State of New York, County of Kings,
between plaintiff SHAUL KOPELOWITZ (the “Judgment Creditor”), and defendants TOBY
MOSKOWITZ and MICHAEL a/k/a YECHIEL LICHTENSTEIN (the “Judgment Debtor(s)”), a
judgment was duly entered on December 16, 2019, in favor of the Judgment Creditor and against
the Judgment Debtors (the “Judgment”), in the sum of $6,350,225.00; and
WHEREAS, the witness has an office for the regular transaction of business in person in New
York County; and
WHEREAS, the judgment debtor’s last known addresses are as follows:
Toby Moskowitz
137-55 71st Ave.,
Flushing, New York 11367
Michael a/k/a Yechiel Lichtenstein
929 E 5th Street
Brooklyn, New York 11230
WE COMMAND YOU, pursuant to CPLR 5224, that all business and excuses being
laid aside, to produce and permit the party seeking discovery, or someone acting on his or her
behalf, to inspect, copy, test or photograph at the Law Office of Jeffrey Fleischmann PC,
FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019
NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021
attorneys for the Plaintiff herein, located at 150 Broadway, Suite 900, New York, New York
10038, on December 1, 2020 at 10:00 am and at any recessed or adjourned date, all documents
or any things which are in the possession, custody or control designated as follows:
All books, records and papers in your possession, custody or control relating to all funds
or accounts held, directly or indirectly, or in escrow, related to, by or on behalf of TOBY
MOSKOWITZ a/k/a TOBY MOSKOVITS and/or MICHAEL a/k/a YECHIEL
LICHTENSTEIN and any entities in which TOBY MOSKOWITZ a/k/a TOBY
MOSKOVITS and/or MICHAEL a/k/a YECHIEL LICHTENSTEIN have a direct or
indirect interest, including without limitation, GRAND LIVING LLC, 96 WYTHE
ACQUISITION LLC, 19 KENT DEVELOPMENT LLC, 232 SEIGEN ACQUISITION
LLC, 564 ST. JOHNS LLC and 564 ST. JOHNS ACQUISITION LLC, and copies of all
proof of such funds, including account opening documents, tax documents, tax returns, account
closing documents, operating agreements, formation documents, authorized signatories, deposits,
wire transfers, funds held in escrow, escrow accounts, and account statements to and from said
accounts,, including copies of the checks (front and back) and deposit slips (front and back), and
copies of all checks (front and back) written against, or deposited in, said accounts or funds, and
the names, telephone numbers, and addresses of all authorized signatories on such accounts,
from January 1, 2015 until the present date.
You may comply with the within subpoena duces tecum by having the requisite
documents and things produced by a person able to identify them and testify respecting their
origin, purpose and custody at the Law Office of Jeffrey Fleischmann PC on or December 1,
2020. CPLR 2305(b).
2
FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019
NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021
PLEASE TAKE FURTHER NOTICE THAT, failure to comply with this Subpoena is
punishable as a contempt of court and shall make you liable to the person on whose behalf this
Subpoena was issued for a penalty not to exceed Fifty Dollars and all damages sustained by
reason of your failure to comply.
I HEREBY CERTIFY THAT THIS INFORMATION SUBPOENA COMPLIES WITH
RULE 5224 OF THE CIVIL PRACTICE LAW AND RULES AND THAT I HAVE A
REASONABLE BELIEF THAT THE PARTY RECEIVING THE SUBPOENA HAS IN THEIR
POSSESSION INFORMATION ABOUT THE DEBTOR THAT WILL ASSIST THE
CREDITOR IN COLLECTING THE JUDGMENT.
Dated: New York, New York
November 12, 2020
LAW OFFICE OF JEFFREY FLEISCHMANN PC
By: __________________________
Jeffrey Fleischmann, Esq.
Attorneys for Plaintiff Shaul Kopelowitz
150 Broadway, Suite 900
New York, New York 10038
Tel. (646) 657-9623
Fax (646) 351-0694
jf@lawjf.com
.
3
FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019
NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X
: Index No. 527036/2019
SHAUL KOPELOWITZ, :
: SUBPOENA DUCES TECUM
Plaintiff, :
:
- against - :
:
TOBY MOSKOWITZ and MICHAEL a/k/a YECHIEL :
LICHTENSTEIN, :
:
Defendants. :
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X
TO: 232 Seigen Acquisition LLC a/k/a 232 Seigel Acquisition LLC
Address: 1274 49th Street, Suite 184
Brooklyn, New York 11219
GREETINGS:
WHEREAS, in an action in the Supreme Court of the State of New York, County of Kings,
between plaintiff SHAUL KOPELOWITZ (the “Judgment Creditor”), and defendants TOBY
MOSKOWITZ and MICHAEL a/k/a YECHIEL LICHTENSTEIN (the “Judgment Debtor(s)”), a
judgment was duly entered on December 16, 2019, in favor of the Judgment Creditor and against
the Judgment Debtors (the “Judgment”), in the sum of $6,350,225.00; and
WHEREAS, the witness has an office for the regular transaction of business in person in New
York County; and
WHEREAS, the Judgment Debtors’ last known addresses are as follows:
Toby Moskowitz
137-55 71st Ave.,
Flushing, New York 11367
Michael a/k/a Yechiel Lichtenstein
929 E 5th Street
Brooklyn, New York 11230
WE COMMAND YOU, pursuant to CPLR §5224, that all business and excuses being
laid aside, to produce and permit the party seeking discovery, or someone acting on his or her
behalf, to inspect, copy, test or photograph at the Law Office of Jeffrey Fleischmann PC,
FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019
NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021
attorneys for the Plaintiff herein, located at 150 Broadway, Suite 900, New York, New York
10038, on December 1, 2020 at 10:00 am and at any recessed or adjourned date, all documents
or any things which are in the possession, custody or control designated as follows:
All books, records and papers in your possession, custody or control relating to all funds
or accounts held, directly or indirectly, or in escrow, related to, by or on behalf of TOBY
MOSKOWITZ a/k/a TOBY MOSKOVITS and/or MICHAEL a/k/a YECHIEL
LICHTENSTEIN and any entities in which TOBY MOSKOWITZ a/k/a TOBY
MOSKOVITS and/or MICHAEL a/k/a YECHIEL LICHTENSTEIN have a direct or
indirect interest, including without limitation, GRAND LIVING LLC, 96 WYTHE
ACQUISITION LLC, 19 KENT DEVELOPMENT LLC, 215 MOORE ST ACQUISITION
LLC, 564 ST. JOHNS LLC and 564 ST. JOHNS ACQUISITION LLC, and copies of all
proof of such funds, including account opening documents, tax documents, tax returns, account
closing documents, operating agreements, formation documents, authorized signatories, deposits,
wire transfers, funds held in escrow, escrow accounts, and account statements to and from said
accounts,, including copies of the checks (front and back) and deposit slips (front and back), and
copies of all checks (front and back) written against, or deposited in, said accounts or funds, and
the names, telephone numbers, and addresses of all authorized signatories on such accounts,
from January 1, 2015 until the present date.
You may comply with the within subpoena duces tecum by having the requisite
documents and things produced by a person able to identify them and testify respecting their
origin, purpose and custody at the Law Office of Jeffrey Fleischmann PC on or before December
1, 2020. CPLR 2305(b).
2
FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019
NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021
PLEASE TAKE FURTHER NOTICE THAT, failure to comply with this Subpoena is
punishable as a contempt of court and shall make you liable to the person on whose behalf this
Subpoena was issued for a penalty not to exceed Fifty Dollars and all damages sustained by
reason of your failure to comply.
I HEREBY CERTIFY THAT THIS INFORMATION SUBPOENA COMPLIES WITH
RULE 5224 OF THE CIVIL PRACTICE LAW AND RULES AND THAT I HAVE A
REASONABLE BELIEF THAT THE PARTY RECEIVING THE SUBPOENA HAS IN THEIR
POSSESSION INFORMATION ABOUT THE DEBTOR THAT WILL ASSIST THE
CREDITOR IN COLLECTING THE JUDGMENT.
Dated: New York, New York
November 12, 2020
LAW OFFICE OF JEFFREY FLEISCHMANN PC
By: __________________________
Jeffrey Fleischmann, Esq.
Attorneys for Plaintiff Shaul Kopelowitz
150 Broadway, Suite 900
New York, New York 10038
Tel. (646) 657-9623
Fax (646) 351-0694
jf@lawjf.com
.
3
FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019
NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X
: Index No. 527036/2019
SHAUL KOPELOWITZ, :
: SUBPOENA DUCES TECUM
Plaintiff, :
:
- against - :
:
TOBY MOSKOWITZ and MICHAEL a/k/a YECHIEL :
LICHTENSTEIN, :
:
Defendants. :
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X
TO: 564 St. Johns Acquisition LLC
Address: 1274 49th Street, Suite 184
Brooklyn, NY 11219
GREETINGS:
WHEREAS, in an action in the Supreme Court of the State of New York, County of Kings,
between plaintiff SHAUL KOPELOWITZ (the “Judgment Creditor”), and defendants TOBY
MOSKOWITZ and MICHAEL a/k/a YECHIEL LICHTENSTEIN (the “Judgment Debtor(s)”), a
judgment was duly entered on December 16, 2019, in favor of the Judgment Creditor and against
the Judgment Debtors (the “Judgment”), in the sum of $6,350,225.00; and
WHEREAS, the witness has an office for the regular transaction of business in person in New
York County; and
WHEREAS, the judgment debtor’s last known addresses are as follows:
Toby Moskowitz
137-55 71st Ave.,
Flushing, New York 11367
Michael a/k/a Yechiel Lichtenstein
929 E 5th Street
Brooklyn, New York 11230
WE COMMAND YOU, pursuant to CPLR 5224, that all business and excuses being
laid aside, to produce and permit the party seeking discovery, or someone acting on his or her
behalf, to inspect, copy, test or photograph at the Law Office of Jeffrey Fleischmann PC,
FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019
NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021
attorneys for the Plaintiff herein, located at 150 Broadway, Suite 900, New York, New York
10038, on December 1, 2020 at 10:00 am and at any recessed or adjourned date, all documents
or any things which are in the possession, custody or control designated as follows:
All books, records and papers in your possession, custody or control relating to all funds
or accounts held, directly or indirectly, or in escrow, related to, by or on behalf of TOBY
MOSKOWITZ a/k/a TOBY MOSKOVITS and/or MICHAEL a/k/a YECHIEL
LICHTENSTEIN and any entities in which TOBY MOSKOWITZ a/k/a TOBY
MOSKOVITS and/or MICHAEL a/k/a YECHIEL LICHTENSTEIN have a direct or
indirect interest, including without limitation, GRAND LIVING LLC, 96 WYTHE
ACQUISITION LLC, 19 KENT DEVELOPMENT LLC, 215 MOORE ST ACQUISITION
LLC, and 232 SEIGEN ACQUISITION LLC, and copies of all proof of such funds, including
account opening documents, tax documents, tax returns, account closing documents, operating
agreements, formation documents, authorized signatories, deposits, wire transfers, funds held in
escrow, escrow accounts, and account statements to and from said accounts,, including copies of
the checks (front and back) and deposit slips (front and back), and copies of all checks (front
and back) written against, or deposited in, said accounts or funds, and the names, telephone
numbers, and addresses of all authorized signatories on such accounts, from January 1, 2015
until the present date.
You may comply with the within subpoena duces tecum by having the requisite
documents and things produced by a person able to identify them and testify respecting their
origin, purpose and custody at the Law Office of Jeffrey Fleischmann PC on or before December
1, 2020. CPLR 2305(b).
2
FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019
NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021
PLEASE TAKE FURTHER NOTICE THAT, failure to comply with this Subpoena is
punishable as a contempt of court and shall make you liable to the person on whose behalf this
Subpoena was issued for a penalty not to exceed Fifty Dollars and all damages sustained by
reason of your failure to comply.
I HEREBY CERTIFY THAT THIS INFORMATION SUBPOENA COMPLIES WITH
RULE 5224 OF THE CIVIL PRACTICE LAW AND RULES AND THAT I HAVE A
REASONABLE BELIEF THAT THE PARTY RECEIVING THE SUBPOENA HAS IN THEIR
POSSESSION INFORMATION ABOUT THE DEBTOR THAT WILL ASSIST THE
CREDITOR IN COLLECTING THE JUDGMENT.
Dated: New York, New York
November 12, 2020
LAW OFFICE OF JEFFREY FLEISCHMANN PC
By: __________________________
Jeffrey Fleischmann, Esq.
Attorneys for Plaintiff Shaul Kopelowitz
150 Broadway, Suite 900
New York, New York 10038
Tel. (646) 657-9623
Fax (646) 351-0694
jf@lawjf.com
.
3
FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019
NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X
: Index No. 527036/2019
SHAUL KOPELOWITZ, :
: SUBPOENA DUCES TECUM
Plaintiff, :
:
- against - :
:
TOBY MOSKOWITZ and MICHAEL a/k/a YECHIEL :
LICHTENSTEIN, :
:
Defendants. :
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X
TO: Grand Living, LLC
Address: 1274 49th Street, STE 184
Brooklyn, New York 11219
GREETINGS:
WHEREAS, in an action in the Supreme Court of the State of New York, County of Kings,
between plaintiff SHAUL KOPELOWITZ (the “Judgment Creditor”), and defendants TOBY
MOSKOWITZ and MICHAEL a/k/a YECHIEL LICHTENSTEIN (the “Judgment Debtor(s)”), a
judgment was duly entered on December 16, 2019, in favor of the Judgment Creditor and against
the Judgment Debtors (the “Judgment”), in the sum of $6,350,225.00; and
WHEREAS, the witness has an office for the regular transaction of business in person in New
York County; and
WHEREAS, the judgment debtor’s last known addresses are as follows:
Toby Moskowitz
137-55 71st Ave.
Flushing, New York 11367
Michael a/k/a Yechiel Lichtenstein
929 E 5th Street
Brooklyn, New York 11230
WE COMMAND YOU, pursuant to CPLR 5224, that all business and excuses being
laid aside, to produce and permit the party seeking discovery, or someone acting on his or her
behalf, to inspect, copy, test or photograph at the Law Office of Jeffrey Fleischmann PC,
FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019
NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021
attorneys for the Plaintiff herein, located at 150 Broadway, Suite 900, New York, New York
10038, on December 1, 2020 at 10:00 am and at any recessed or adjourned date, all documents
or any things which are in the possession, custody or control designated as follows:
All books, records and papers in your possession, custody or control relating to all funds
or accounts held, directly or indirectly, or in escrow, related to, by or on behalf of TOBY
MOSKOWITZ a/k/a TOBY MOSKOVITS and/or MICHAEL a/k/a YECHIEL
LICHTENSTEIN and any entities in which TOBY MOSKOWITZ a/k/a TOBY
MOSKOVITS and/or MICHAEL a/k/a YECHIEL LICHTENSTEIN have a direct or
indirect interest, including without limitation, 96 WYTHE ACQUISITION LLC, 19 KENT
DEVELOPMENT LLC, 215 MOORE ST ACQUISITION LLC, 232 SEIGEN
ACQUISITION LLC, 564 ST. JOHNS LLC and 564 ST. JOHNS ACQUISITION LLC,
and copies of all proof of such funds, including account opening documents, tax documents, tax
returns, account closing documents, operating agreements, formation documents, authorized
signatories, deposits, wire transfers, funds held in escrow, escrow accounts, and account
statements to and from said accounts, including copies of the checks (front and back) and
deposit slips (front and back), and copies of all checks (front and back) written against, or
deposited in, said accounts or funds, and the names, telephone numbers, and addresses of all
authorized signatories on su
Preview
FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019 NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021 EXHIBIT E FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019 NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X : Index No. 527036/2019 SHAUL KOPELOWITZ, : : SUBPOENA DUCES TECUM Plaintiff, : : - against - : : TOBY MOSKOWITZ and MICHAEL a/k/a YECHIEL : LICHTENSTEIN, : : Defendants. : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X TO: 19 Kent Development LLC Address: 199 Lee Avenue, #693 Brooklyn, New York 11211 GREETINGS: WHEREAS, in an action in the Supreme Court of the State of New York, County of Kings, between plaintiff SHAUL KOPELOWITZ (the “Judgment Creditor”), and defendants TOBY MOSKOWITZ and MICHAEL a/k/a YECHIEL LICHTENSTEIN (the “Judgment Debtor(s)”), a judgment was duly entered on December 16, 2019, in favor of the Judgment Creditor and against the Judgment Debtors (the “Judgment”), in the sum of $6,350,225.00; and WHEREAS, the witness has an office for the regular transaction of business in person in New York County; and WHEREAS, the judgment debtor’s last known addresses are as follows: Toby Moskowitz 137-55 71st Ave., Flushing, New York 11367 Michael a/k/a Yechiel Lichtenstein 929 E 5th Street Brooklyn, New York 11230 WE COMMAND YOU, pursuant to CPLR 5224, that all business and excuses being laid aside, to produce and permit the party seeking discovery, or someone acting on his or her behalf, to inspect, copy, test or photograph at the Law Office of Jeffrey Fleischmann PC, FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019 NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021 attorneys for the Plaintiff herein, located at 150 Broadway, Suite 900, New York, New York 10038, on December 1, 2020 at 10:00 am and at any recessed or adjourned date, all documents or any things which are in the possession, custody or control designated as follows: All books, records and papers in your possession, custody or control relating to all funds or accounts held, directly or indirectly, or in escrow, related to, by or on behalf of TOBY MOSKOWITZ a/k/a TOBY MOSKOVITS and/or MICHAEL a/k/a YECHIEL LICHTENSTEIN and any entities in which TOBY MOSKOWITZ a/k/a TOBY MOSKOVITS and/or MICHAEL a/k/a YECHIEL LICHTENSTEIN have a direct or indirect interest, including without limitation, GRAND LIVING LLC, 96 WYTHE ACQUISITION LLC, 215 MOORE ST ACQUISITION LLC, 232 SEIGEN ACQUISITION LLC, 564 ST. JOHNS LLC and 564 ST. JOHNS ACQUISITION LLC, and copies of all proof of such funds, including account opening documents, tax documents, tax returns, account closing documents, operating agreements, formation documents, authorized signatories, deposits, wire transfers, funds held in escrow, escrow accounts, and account statements to and from said accounts, including copies of the checks (front and back) and deposit slips (front and back), and copies of all checks (front and back) written against, or deposited in, said accounts or funds, and the names, telephone numbers, and addresses of all authorized signatories on such accounts, from January 1, 2015 until the present date. You may comply with the within subpoena duces tecum by having the requisite documents and things produced by a person able to identify them and testify respecting their origin, purpose and custody at the Law Office of Jeffrey Fleischmann PC on or before December 1, 2020. CPLR 2305(b). 2 FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019 NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021 PLEASE TAKE FURTHER NOTICE THAT, failure to comply with this Subpoena is punishable as a contempt of court and shall make you liable to the person on whose behalf this Subpoena was issued for a penalty not to exceed Fifty Dollars and all damages sustained by reason of your failure to comply. I HEREBY CERTIFY THAT THIS INFORMATION SUBPOENA COMPLIES WITH RULE 5224 OF THE CIVIL PRACTICE LAW AND RULES AND THAT I HAVE A REASONABLE BELIEF THAT THE PARTY RECEIVING THE SUBPOENA HAS IN THEIR POSSESSION INFORMATION ABOUT THE DEBTOR THAT WILL ASSIST THE CREDITOR IN COLLECTING THE JUDGMENT. Dated: New York, New York November 12, 2020 LAW OFFICE OF JEFFREY FLEISCHMANN PC By: __________________________ Jeffrey Fleischmann, Esq. Attorneys for Plaintiff Shaul Kopelowitz 150 Broadway, Suite 900 New York, New York 10038 Tel. (646) 657-9623 Fax (646) 351-0694 jf@lawjf.com . 3 FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019 NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X : Index No. 527036/2019 SHAUL KOPELOWITZ, : : SUBPOENA DUCES TECUM Plaintiff, : : - against - : : TOBY MOSKOWITZ and MICHAEL a/k/a YECHIEL : LICHTENSTEIN, : : Defendants. : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X TO: 96 Wythe Acquisition LLC Address: 1274 49th Street, #184 Brooklyn, New York 11219 GREETINGS: WHEREAS, in an action in the Supreme Court of the State of New York, County of Kings, between plaintiff SHAUL KOPELOWITZ (the “Judgment Creditor”), and defendants TOBY MOSKOWITZ and MICHAEL a/k/a YECHIEL LICHTENSTEIN (the “Judgment Debtor(s)”), a judgment was duly entered on December 16, 2019, in favor of the Judgment Creditor and against the Judgment Debtors (the “Judgment”), in the sum of $6,350,225.00; and WHEREAS, the witness has an office for the regular transaction of business in person in New York County; and WHEREAS, the judgment debtor’s last known addresses are as follows: Toby Moskowitz 137-55 71st Ave., Flushing, New York 11367 Michael a/k/a Yechiel Lichtenstein 929 E 5th Street Brooklyn, New York 11230 WE COMMAND YOU, pursuant to CPLR 5224, that all business and excuses being laid aside, to produce and permit the party seeking discovery, or someone acting on his or her behalf, to inspect, copy, test or photograph at the Law Office of Jeffrey Fleischmann PC, FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019 NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021 attorneys for the Plaintiff herein, located at 150 Broadway, Suite 900, New York, New York 10038, on December 1, 2020 at 10:00 am and at any recessed or adjourned date, all documents or any things which are in the possession, custody or control designated as follows: All books, records and papers in your possession, custody or control relating to all funds or accounts held, directly or indirectly, or in escrow, related to, by or on behalf of TOBY MOSKOWITZ a/k/a TOBY MOSKOVITS and/or MICHAEL a/k/a YECHIEL LICHTENSTEIN and any entities in which TOBY MOSKOWITZ a/k/a TOBY MOSKOVITS and/or MICHAEL a/k/a YECHIEL LICHTENSTEIN have a direct or indirect interest, including without limitation, GRAND LIVING LLC, 19 KENT DEVELOPMENT LLC, 215 MOORE ST ACQUISITION LLC, 232 SEIGEN ACQUISITION LLC, 564 ST. JOHNS LLC and 564 ST. JOHNS ACQUISITION LLC, and copies of all proof of such funds, including account opening documents, tax documents, tax returns, account closing documents, operating agreements, formation documents, authorized signatories, deposits, wire transfers, funds held in escrow, escrow accounts, and account statements to and from said accounts,, including copies of the checks (front and back) and deposit slips (front and back), and copies of all checks (front and back) written against, or deposited in, said accounts or funds, and the names, telephone numbers, and addresses of all authorized signatories on such accounts, from January 1, 2015 until the present date. You may comply with the within subpoena duces tecum by having the requisite documents and things produced by a person able to identify them and testify respecting their origin, purpose and custody at the Law Office of Jeffrey Fleischmann PC on or before December 1, 2020. CPLR 2305(b). 2 FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019 NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021 PLEASE TAKE FURTHER NOTICE THAT, failure to comply with this Subpoena is punishable as a contempt of court and shall make you liable to the person on whose behalf this Subpoena was issued for a penalty not to exceed Fifty Dollars and all damages sustained by reason of your failure to comply. I HEREBY CERTIFY THAT THIS INFORMATION SUBPOENA COMPLIES WITH RULE 5224 OF THE CIVIL PRACTICE LAW AND RULES AND THAT I HAVE A REASONABLE BELIEF THAT THE PARTY RECEIVING THE SUBPOENA HAS IN THEIR POSSESSION INFORMATION ABOUT THE DEBTOR THAT WILL ASSIST THE CREDITOR IN COLLECTING THE JUDGMENT. Dated: New York, New York November 12, 2020 LAW OFFICE OF JEFFREY FLEISCHMANN PC By: __________________________ Jeffrey Fleischmann, Esq. Attorneys for Plaintiff Shaul Kopelowitz 150 Broadway, Suite 900 New York, New York 10038 Tel. (646) 657-9623 Fax (646) 351-0694 jf@lawjf.com . 3 FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019 NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X : Index No. 527036/2019 SHAUL KOPELOWITZ, : : SUBPOENA DUCES TECUM Plaintiff, : : - against - : : TOBY MOSKOWITZ and MICHAEL a/k/a YECHIEL : LICHTENSTEIN, : : Defendants. : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X TO: 215 Moore St Acquisition LLC Address: 1274 49th Street, Ste 184 Brooklyn, New York 11219 GREETINGS: WHEREAS, in an action in the Supreme Court of the State of New York, County of Kings, between plaintiff SHAUL KOPELOWITZ (the “Judgment Creditor”), and defendants TOBY MOSKOWITZ and MICHAEL a/k/a YECHIEL LICHTENSTEIN (the “Judgment Debtor(s)”), a judgment was duly entered on December 16, 2019, in favor of the Judgment Creditor and against the Judgment Debtors (the “Judgment”), in the sum of $6,350,225.00; and WHEREAS, the witness has an office for the regular transaction of business in person in New York County; and WHEREAS, the judgment debtor’s last known addresses are as follows: Toby Moskowitz 137-55 71st Ave., Flushing, New York 11367 Michael a/k/a Yechiel Lichtenstein 929 E 5th Street Brooklyn, New York 11230 WE COMMAND YOU, pursuant to CPLR 5224, that all business and excuses being laid aside, to produce and permit the party seeking discovery, or someone acting on his or her behalf, to inspect, copy, test or photograph at the Law Office of Jeffrey Fleischmann PC, FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019 NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021 attorneys for the Plaintiff herein, located at 150 Broadway, Suite 900, New York, New York 10038, on December 1, 2020 at 10:00 am and at any recessed or adjourned date, all documents or any things which are in the possession, custody or control designated as follows: All books, records and papers in your possession, custody or control relating to all funds or accounts held, directly or indirectly, or in escrow, related to, by or on behalf of TOBY MOSKOWITZ a/k/a TOBY MOSKOVITS and/or MICHAEL a/k/a YECHIEL LICHTENSTEIN and any entities in which TOBY MOSKOWITZ a/k/a TOBY MOSKOVITS and/or MICHAEL a/k/a YECHIEL LICHTENSTEIN have a direct or indirect interest, including without limitation, GRAND LIVING LLC, 96 WYTHE ACQUISITION LLC, 19 KENT DEVELOPMENT LLC, 232 SEIGEN ACQUISITION LLC, 564 ST. JOHNS LLC and 564 ST. JOHNS ACQUISITION LLC, and copies of all proof of such funds, including account opening documents, tax documents, tax returns, account closing documents, operating agreements, formation documents, authorized signatories, deposits, wire transfers, funds held in escrow, escrow accounts, and account statements to and from said accounts,, including copies of the checks (front and back) and deposit slips (front and back), and copies of all checks (front and back) written against, or deposited in, said accounts or funds, and the names, telephone numbers, and addresses of all authorized signatories on such accounts, from January 1, 2015 until the present date. You may comply with the within subpoena duces tecum by having the requisite documents and things produced by a person able to identify them and testify respecting their origin, purpose and custody at the Law Office of Jeffrey Fleischmann PC on or December 1, 2020. CPLR 2305(b). 2 FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019 NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021 PLEASE TAKE FURTHER NOTICE THAT, failure to comply with this Subpoena is punishable as a contempt of court and shall make you liable to the person on whose behalf this Subpoena was issued for a penalty not to exceed Fifty Dollars and all damages sustained by reason of your failure to comply. I HEREBY CERTIFY THAT THIS INFORMATION SUBPOENA COMPLIES WITH RULE 5224 OF THE CIVIL PRACTICE LAW AND RULES AND THAT I HAVE A REASONABLE BELIEF THAT THE PARTY RECEIVING THE SUBPOENA HAS IN THEIR POSSESSION INFORMATION ABOUT THE DEBTOR THAT WILL ASSIST THE CREDITOR IN COLLECTING THE JUDGMENT. Dated: New York, New York November 12, 2020 LAW OFFICE OF JEFFREY FLEISCHMANN PC By: __________________________ Jeffrey Fleischmann, Esq. Attorneys for Plaintiff Shaul Kopelowitz 150 Broadway, Suite 900 New York, New York 10038 Tel. (646) 657-9623 Fax (646) 351-0694 jf@lawjf.com . 3 FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019 NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X : Index No. 527036/2019 SHAUL KOPELOWITZ, : : SUBPOENA DUCES TECUM Plaintiff, : : - against - : : TOBY MOSKOWITZ and MICHAEL a/k/a YECHIEL : LICHTENSTEIN, : : Defendants. : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X TO: 232 Seigen Acquisition LLC a/k/a 232 Seigel Acquisition LLC Address: 1274 49th Street, Suite 184 Brooklyn, New York 11219 GREETINGS: WHEREAS, in an action in the Supreme Court of the State of New York, County of Kings, between plaintiff SHAUL KOPELOWITZ (the “Judgment Creditor”), and defendants TOBY MOSKOWITZ and MICHAEL a/k/a YECHIEL LICHTENSTEIN (the “Judgment Debtor(s)”), a judgment was duly entered on December 16, 2019, in favor of the Judgment Creditor and against the Judgment Debtors (the “Judgment”), in the sum of $6,350,225.00; and WHEREAS, the witness has an office for the regular transaction of business in person in New York County; and WHEREAS, the Judgment Debtors’ last known addresses are as follows: Toby Moskowitz 137-55 71st Ave., Flushing, New York 11367 Michael a/k/a Yechiel Lichtenstein 929 E 5th Street Brooklyn, New York 11230 WE COMMAND YOU, pursuant to CPLR §5224, that all business and excuses being laid aside, to produce and permit the party seeking discovery, or someone acting on his or her behalf, to inspect, copy, test or photograph at the Law Office of Jeffrey Fleischmann PC, FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019 NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021 attorneys for the Plaintiff herein, located at 150 Broadway, Suite 900, New York, New York 10038, on December 1, 2020 at 10:00 am and at any recessed or adjourned date, all documents or any things which are in the possession, custody or control designated as follows: All books, records and papers in your possession, custody or control relating to all funds or accounts held, directly or indirectly, or in escrow, related to, by or on behalf of TOBY MOSKOWITZ a/k/a TOBY MOSKOVITS and/or MICHAEL a/k/a YECHIEL LICHTENSTEIN and any entities in which TOBY MOSKOWITZ a/k/a TOBY MOSKOVITS and/or MICHAEL a/k/a YECHIEL LICHTENSTEIN have a direct or indirect interest, including without limitation, GRAND LIVING LLC, 96 WYTHE ACQUISITION LLC, 19 KENT DEVELOPMENT LLC, 215 MOORE ST ACQUISITION LLC, 564 ST. JOHNS LLC and 564 ST. JOHNS ACQUISITION LLC, and copies of all proof of such funds, including account opening documents, tax documents, tax returns, account closing documents, operating agreements, formation documents, authorized signatories, deposits, wire transfers, funds held in escrow, escrow accounts, and account statements to and from said accounts,, including copies of the checks (front and back) and deposit slips (front and back), and copies of all checks (front and back) written against, or deposited in, said accounts or funds, and the names, telephone numbers, and addresses of all authorized signatories on such accounts, from January 1, 2015 until the present date. You may comply with the within subpoena duces tecum by having the requisite documents and things produced by a person able to identify them and testify respecting their origin, purpose and custody at the Law Office of Jeffrey Fleischmann PC on or before December 1, 2020. CPLR 2305(b). 2 FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019 NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021 PLEASE TAKE FURTHER NOTICE THAT, failure to comply with this Subpoena is punishable as a contempt of court and shall make you liable to the person on whose behalf this Subpoena was issued for a penalty not to exceed Fifty Dollars and all damages sustained by reason of your failure to comply. I HEREBY CERTIFY THAT THIS INFORMATION SUBPOENA COMPLIES WITH RULE 5224 OF THE CIVIL PRACTICE LAW AND RULES AND THAT I HAVE A REASONABLE BELIEF THAT THE PARTY RECEIVING THE SUBPOENA HAS IN THEIR POSSESSION INFORMATION ABOUT THE DEBTOR THAT WILL ASSIST THE CREDITOR IN COLLECTING THE JUDGMENT. Dated: New York, New York November 12, 2020 LAW OFFICE OF JEFFREY FLEISCHMANN PC By: __________________________ Jeffrey Fleischmann, Esq. Attorneys for Plaintiff Shaul Kopelowitz 150 Broadway, Suite 900 New York, New York 10038 Tel. (646) 657-9623 Fax (646) 351-0694 jf@lawjf.com . 3 FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019 NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X : Index No. 527036/2019 SHAUL KOPELOWITZ, : : SUBPOENA DUCES TECUM Plaintiff, : : - against - : : TOBY MOSKOWITZ and MICHAEL a/k/a YECHIEL : LICHTENSTEIN, : : Defendants. : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X TO: 564 St. Johns Acquisition LLC Address: 1274 49th Street, Suite 184 Brooklyn, NY 11219 GREETINGS: WHEREAS, in an action in the Supreme Court of the State of New York, County of Kings, between plaintiff SHAUL KOPELOWITZ (the “Judgment Creditor”), and defendants TOBY MOSKOWITZ and MICHAEL a/k/a YECHIEL LICHTENSTEIN (the “Judgment Debtor(s)”), a judgment was duly entered on December 16, 2019, in favor of the Judgment Creditor and against the Judgment Debtors (the “Judgment”), in the sum of $6,350,225.00; and WHEREAS, the witness has an office for the regular transaction of business in person in New York County; and WHEREAS, the judgment debtor’s last known addresses are as follows: Toby Moskowitz 137-55 71st Ave., Flushing, New York 11367 Michael a/k/a Yechiel Lichtenstein 929 E 5th Street Brooklyn, New York 11230 WE COMMAND YOU, pursuant to CPLR 5224, that all business and excuses being laid aside, to produce and permit the party seeking discovery, or someone acting on his or her behalf, to inspect, copy, test or photograph at the Law Office of Jeffrey Fleischmann PC, FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019 NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021 attorneys for the Plaintiff herein, located at 150 Broadway, Suite 900, New York, New York 10038, on December 1, 2020 at 10:00 am and at any recessed or adjourned date, all documents or any things which are in the possession, custody or control designated as follows: All books, records and papers in your possession, custody or control relating to all funds or accounts held, directly or indirectly, or in escrow, related to, by or on behalf of TOBY MOSKOWITZ a/k/a TOBY MOSKOVITS and/or MICHAEL a/k/a YECHIEL LICHTENSTEIN and any entities in which TOBY MOSKOWITZ a/k/a TOBY MOSKOVITS and/or MICHAEL a/k/a YECHIEL LICHTENSTEIN have a direct or indirect interest, including without limitation, GRAND LIVING LLC, 96 WYTHE ACQUISITION LLC, 19 KENT DEVELOPMENT LLC, 215 MOORE ST ACQUISITION LLC, and 232 SEIGEN ACQUISITION LLC, and copies of all proof of such funds, including account opening documents, tax documents, tax returns, account closing documents, operating agreements, formation documents, authorized signatories, deposits, wire transfers, funds held in escrow, escrow accounts, and account statements to and from said accounts,, including copies of the checks (front and back) and deposit slips (front and back), and copies of all checks (front and back) written against, or deposited in, said accounts or funds, and the names, telephone numbers, and addresses of all authorized signatories on such accounts, from January 1, 2015 until the present date. You may comply with the within subpoena duces tecum by having the requisite documents and things produced by a person able to identify them and testify respecting their origin, purpose and custody at the Law Office of Jeffrey Fleischmann PC on or before December 1, 2020. CPLR 2305(b). 2 FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019 NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021 PLEASE TAKE FURTHER NOTICE THAT, failure to comply with this Subpoena is punishable as a contempt of court and shall make you liable to the person on whose behalf this Subpoena was issued for a penalty not to exceed Fifty Dollars and all damages sustained by reason of your failure to comply. I HEREBY CERTIFY THAT THIS INFORMATION SUBPOENA COMPLIES WITH RULE 5224 OF THE CIVIL PRACTICE LAW AND RULES AND THAT I HAVE A REASONABLE BELIEF THAT THE PARTY RECEIVING THE SUBPOENA HAS IN THEIR POSSESSION INFORMATION ABOUT THE DEBTOR THAT WILL ASSIST THE CREDITOR IN COLLECTING THE JUDGMENT. Dated: New York, New York November 12, 2020 LAW OFFICE OF JEFFREY FLEISCHMANN PC By: __________________________ Jeffrey Fleischmann, Esq. Attorneys for Plaintiff Shaul Kopelowitz 150 Broadway, Suite 900 New York, New York 10038 Tel. (646) 657-9623 Fax (646) 351-0694 jf@lawjf.com . 3 FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019 NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X : Index No. 527036/2019 SHAUL KOPELOWITZ, : : SUBPOENA DUCES TECUM Plaintiff, : : - against - : : TOBY MOSKOWITZ and MICHAEL a/k/a YECHIEL : LICHTENSTEIN, : : Defendants. : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X TO: Grand Living, LLC Address: 1274 49th Street, STE 184 Brooklyn, New York 11219 GREETINGS: WHEREAS, in an action in the Supreme Court of the State of New York, County of Kings, between plaintiff SHAUL KOPELOWITZ (the “Judgment Creditor”), and defendants TOBY MOSKOWITZ and MICHAEL a/k/a YECHIEL LICHTENSTEIN (the “Judgment Debtor(s)”), a judgment was duly entered on December 16, 2019, in favor of the Judgment Creditor and against the Judgment Debtors (the “Judgment”), in the sum of $6,350,225.00; and WHEREAS, the witness has an office for the regular transaction of business in person in New York County; and WHEREAS, the judgment debtor’s last known addresses are as follows: Toby Moskowitz 137-55 71st Ave. Flushing, New York 11367 Michael a/k/a Yechiel Lichtenstein 929 E 5th Street Brooklyn, New York 11230 WE COMMAND YOU, pursuant to CPLR 5224, that all business and excuses being laid aside, to produce and permit the party seeking discovery, or someone acting on his or her behalf, to inspect, copy, test or photograph at the Law Office of Jeffrey Fleischmann PC, FILED: KINGS COUNTY CLERK 05/19/2021 05:07 PM INDEX NO. 527036/2019 NYSCEF DOC. NO. 167 RECEIVED NYSCEF: 05/19/2021 attorneys for the Plaintiff herein, located at 150 Broadway, Suite 900, New York, New York 10038, on December 1, 2020 at 10:00 am and at any recessed or adjourned date, all documents or any things which are in the possession, custody or control designated as follows: All books, records and papers in your possession, custody or control relating to all funds or accounts held, directly or indirectly, or in escrow, related to, by or on behalf of TOBY MOSKOWITZ a/k/a TOBY MOSKOVITS and/or MICHAEL a/k/a YECHIEL LICHTENSTEIN and any entities in which TOBY MOSKOWITZ a/k/a TOBY MOSKOVITS and/or MICHAEL a/k/a YECHIEL LICHTENSTEIN have a direct or indirect interest, including without limitation, 96 WYTHE ACQUISITION LLC, 19 KENT DEVELOPMENT LLC, 215 MOORE ST ACQUISITION LLC, 232 SEIGEN ACQUISITION LLC, 564 ST. JOHNS LLC and 564 ST. JOHNS ACQUISITION LLC, and copies of all proof of such funds, including account opening documents, tax documents, tax returns, account closing documents, operating agreements, formation documents, authorized signatories, deposits, wire transfers, funds held in escrow, escrow accounts, and account statements to and from said accounts, including copies of the checks (front and back) and deposit slips (front and back), and copies of all checks (front and back) written against, or deposited in, said accounts or funds, and the names, telephone numbers, and addresses of all authorized signatories on su