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FILED: KINGS COUNTY CLERK 08/30/2021 10:00 AM INDEX NO. 515251/2021
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 08/30/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
------------------------------------------------------------------------X Index No.: 515251/2021
PRESTIGE HOME FITNESS, LLC A/K/A GYMGUYZ .,
BAY RIDGE
Plaintiff, Notice of Motion
-against-
GYMGUYZ FRANCHISING, LLC,
Defendant.
------------------------------------------------------------------------X
SIRS:
PLEASE TAKE NOTICE that upon the annexed affirmation of the undersigned, with
annexed exhibits, and all the prior pleadings and proceedings heretofore had herein, the Plaintiff,
PRESTIGE HOME FITNESS, LLC A/K/A GYMGUYZ BAY RIDGE., will move this Court at an
IAS Part of the SUPREME COURT OF THE STATE OF NEW YORK, County of Kings, located
at 360 Adams Street, Brooklyn, New York, 11201 on the ___th
30 day of September, 2021, at 9:30
in the forenoon of that day, or as soon thereafter as counsel may be heard, for an Order granting
default judgment, pursuant to CPLR 3215, in favor of the Plaintiff and against the Defendant,
declaring the rights of the parties, directing an accounting, and awarding judgment in an amount to
be determined at inquest; along with interest, costs, disbursements, and such and other further relief
as may be just, proper, and equitable.
PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR § 2214(b), all answering
papers, if any, including without limitation answering affidavits and other papers to be used in
opposition hereto, shall be served at least seven (7) days before the return date of this motion.
Dated: August 27, 2021
Brooklyn, New York Yours, etc.,
Kopelevich & Feldsherova, P.C.
To: Attorney(s) for Plaintiff(s)
GYMGUYZ FRANCHISING LLC 241 37th Street, Suite B439
1 Dupont Street, Suite 108 Brooklyn, NY 11232
Plainview, NY 11803 (718) 332-0577
By:_____________________________
DAVID LANDFAIR
1 of 2
FILED: KINGS COUNTY CLERK 08/30/2021 10:00 AM INDEX NO. 515251/2021
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 08/30/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS Index No.: 515251/2021
PRESTIGE HOME FITNESS, LLC, a/k/a GYMGUYZ
BAY RIDGE.,
Plaintiff(s),
-against-
GYMGUYZ FRANCHISING, LLC
Defendant(s).
NOTICE OF MOTION FOR DEFAULT JUDGMENT
KOPELEVICH & FELDSHEROVA, PC
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: August 27, 2021 Signature: ............................................................
Print Signer’s Name: David Landfair
To:
GYMGUYZ FRANCHISING LLC
1 Dupont Street, Suite 108
Plainview, NY 11803
2 of 2
Preview
FILED: KINGS COUNTY CLERK 08/30/2021 10:00 AM INDEX NO. 515251/2021 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 08/30/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ------------------------------------------------------------------------X Index No.: 515251/2021 PRESTIGE HOME FITNESS, LLC A/K/A GYMGUYZ ., BAY RIDGE Plaintiff, Notice of Motion -against- GYMGUYZ FRANCHISING, LLC, Defendant. ------------------------------------------------------------------------X SIRS: PLEASE TAKE NOTICE that upon the annexed affirmation of the undersigned, with annexed exhibits, and all the prior pleadings and proceedings heretofore had herein, the Plaintiff, PRESTIGE HOME FITNESS, LLC A/K/A GYMGUYZ BAY RIDGE., will move this Court at an IAS Part of the SUPREME COURT OF THE STATE OF NEW YORK, County of Kings, located at 360 Adams Street, Brooklyn, New York, 11201 on the ___th 30 day of September, 2021, at 9:30 in the forenoon of that day, or as soon thereafter as counsel may be heard, for an Order granting default judgment, pursuant to CPLR 3215, in favor of the Plaintiff and against the Defendant, declaring the rights of the parties, directing an accounting, and awarding judgment in an amount to be determined at inquest; along with interest, costs, disbursements, and such and other further relief as may be just, proper, and equitable. PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR § 2214(b), all answering papers, if any, including without limitation answering affidavits and other papers to be used in opposition hereto, shall be served at least seven (7) days before the return date of this motion. Dated: August 27, 2021 Brooklyn, New York Yours, etc., Kopelevich & Feldsherova, P.C. To: Attorney(s) for Plaintiff(s) GYMGUYZ FRANCHISING LLC 241 37th Street, Suite B439 1 Dupont Street, Suite 108 Brooklyn, NY 11232 Plainview, NY 11803 (718) 332-0577 By:_____________________________ DAVID LANDFAIR 1 of 2 FILED: KINGS COUNTY CLERK 08/30/2021 10:00 AM INDEX NO. 515251/2021 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 08/30/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS Index No.: 515251/2021 PRESTIGE HOME FITNESS, LLC, a/k/a GYMGUYZ BAY RIDGE., Plaintiff(s), -against- GYMGUYZ FRANCHISING, LLC Defendant(s). NOTICE OF MOTION FOR DEFAULT JUDGMENT KOPELEVICH & FELDSHEROVA, PC 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: August 27, 2021 Signature: ............................................................ Print Signer’s Name: David Landfair To: GYMGUYZ FRANCHISING LLC 1 Dupont Street, Suite 108 Plainview, NY 11803 2 of 2