Preview
FILED: KINGS COUNTY CLERK 09/09/2021 10:03 AM INDEX NO. 515251/2021
NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/09/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
PRESTIGE HOME FITNESS, LLC A/K/A GYMGUYZ
BAY RIDGE NOTICE OF REJECTION OF ANSWER
Plaintiffs,
-against- INDEX NO.: 515251/21
GYMGUYZ FRANCHISING, LLC
File No.:
Defendants
COUNSELOR :
PLEASE TAKE NOTICE that Defendant’s answer is hereby rejected. Defendant’s answer is
untimely pursuant to CPLR 320.
Dated: Brooklyn, NY Kopelevich & Feldsherova, P.C.
September 9, 2021 Attorneys for Plaintiff
241 37th Street, Suite B439
TO: Brooklyn, NY 11225
LASSER LAW GROUP, PLLC
VIA NYSCEF
By:______________________________
David Landfair
1 of 3
FILED: KINGS COUNTY CLERK 09/09/2021 10:03 AM INDEX NO. 515251/2021
NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/09/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
PRESTIGE HOME FITNESS, LLC A/K/A GYMGUYZ
BAY RIDGE NOTICE OF EXAMINATION BEFORE
Plaintiffs, TRIAL
-against-
GYMGUYZ FRANCHISING, LLC INDEX NO.: 515251/21
Defendants
File No.:
SIRS:
PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and Rules, the
testimony, upon oral examination of Defendant GYMGUYZ FRANCHISING, LLC, as witnesses, will be
taken before a before a Notary Public, who is not an attorney, or employee of an attorney, for any party or
prospective party herein and is not a person who would be disqualified to act as a juror because of interest
or because of consanguinity or affinity to any party herein, at 241 37th Street, Suite B439, Brooklyn, New
York, 11232, on the 14th day of October, 2021, at 9:00 in the forenoon of that day with respect to evidence
material and necessary in the prosecution of this action:
All relevant and pertinent facts and circumstances in connection with the within action.
That the said persons to be examined are required to produce at such examination the following:
All written records and electronic or mechanical recordings, regarding the above action,
including notes, memoranda, invoices, diaries, calendars, or outlines prepared in connection
with such testimony.
Dated: Brooklyn, NY Kopelevich & Feldsherova, P.C.
September 9, 2021 Attorneys for Plaintiff
241 37th Street, Suite B439
TO: Brooklyn, NY 11232
LASSER LAW GROUP, PLLC 718-332-0577
VIA NYSCEF
By:______________________________
David Landfair
2 of 3
FILED: KINGS COUNTY CLERK 09/09/2021 10:03 AM INDEX NO. 515251/2021
NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/09/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
PRESTIGE HOME FITNESS, LLC A/K/A GYMGUYZ
BAY RIDGE
Plaintiffs, INDEX NO.: 515251/21
File No.:
-against-
GYMGUYZ FRANCHISING, LLC
Defendants
NOTICE OF REJECTION AND NOTICE OF EBT
Kopelevich & Feldsherova, P.C.
Attorneys for Plaintiff
241 37th Street, Suite B439
Brooklyn, NY 11232
(718) 332-0577
Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney duly admitted to practice in the courts of New
York State, certifies that, upon information and belief and reasonable inquiry, the contentions contained in the
annexed documents are not frivolous.
Dated: September 9, 2021 Signature: .....................................................
Print Signer’s Name: David Landfair ........................
TO:
LASSER LAW GROUP, PLLC
VIA NYSCEF
3 of 3
Preview
FILED: KINGS COUNTY CLERK 09/09/2021 10:03 AM INDEX NO. 515251/2021 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/09/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS PRESTIGE HOME FITNESS, LLC A/K/A GYMGUYZ BAY RIDGE NOTICE OF REJECTION OF ANSWER Plaintiffs, -against- INDEX NO.: 515251/21 GYMGUYZ FRANCHISING, LLC File No.: Defendants COUNSELOR : PLEASE TAKE NOTICE that Defendant’s answer is hereby rejected. Defendant’s answer is untimely pursuant to CPLR 320. Dated: Brooklyn, NY Kopelevich & Feldsherova, P.C. September 9, 2021 Attorneys for Plaintiff 241 37th Street, Suite B439 TO: Brooklyn, NY 11225 LASSER LAW GROUP, PLLC VIA NYSCEF By:______________________________ David Landfair 1 of 3 FILED: KINGS COUNTY CLERK 09/09/2021 10:03 AM INDEX NO. 515251/2021 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/09/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS PRESTIGE HOME FITNESS, LLC A/K/A GYMGUYZ BAY RIDGE NOTICE OF EXAMINATION BEFORE Plaintiffs, TRIAL -against- GYMGUYZ FRANCHISING, LLC INDEX NO.: 515251/21 Defendants File No.: SIRS: PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and Rules, the testimony, upon oral examination of Defendant GYMGUYZ FRANCHISING, LLC, as witnesses, will be taken before a before a Notary Public, who is not an attorney, or employee of an attorney, for any party or prospective party herein and is not a person who would be disqualified to act as a juror because of interest or because of consanguinity or affinity to any party herein, at 241 37th Street, Suite B439, Brooklyn, New York, 11232, on the 14th day of October, 2021, at 9:00 in the forenoon of that day with respect to evidence material and necessary in the prosecution of this action: All relevant and pertinent facts and circumstances in connection with the within action. That the said persons to be examined are required to produce at such examination the following: All written records and electronic or mechanical recordings, regarding the above action, including notes, memoranda, invoices, diaries, calendars, or outlines prepared in connection with such testimony. Dated: Brooklyn, NY Kopelevich & Feldsherova, P.C. September 9, 2021 Attorneys for Plaintiff 241 37th Street, Suite B439 TO: Brooklyn, NY 11232 LASSER LAW GROUP, PLLC 718-332-0577 VIA NYSCEF By:______________________________ David Landfair 2 of 3 FILED: KINGS COUNTY CLERK 09/09/2021 10:03 AM INDEX NO. 515251/2021 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/09/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS PRESTIGE HOME FITNESS, LLC A/K/A GYMGUYZ BAY RIDGE Plaintiffs, INDEX NO.: 515251/21 File No.: -against- GYMGUYZ FRANCHISING, LLC Defendants NOTICE OF REJECTION AND NOTICE OF EBT Kopelevich & Feldsherova, P.C. Attorneys for Plaintiff 241 37th Street, Suite B439 Brooklyn, NY 11232 (718) 332-0577 Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney duly admitted to practice in the courts of New York State, certifies that, upon information and belief and reasonable inquiry, the contentions contained in the annexed documents are not frivolous. Dated: September 9, 2021 Signature: ..................................................... Print Signer’s Name: David Landfair ........................ TO: LASSER LAW GROUP, PLLC VIA NYSCEF 3 of 3