Preview
FILED: KINGS COUNTY CLERK 06/29/2021 12:02 PM INDEX NO. 510844/2016
NYSCEF DOC. NO. 786 RECEIVED NYSCEF: 06/29/2021
EXHIBIT Q
FILED: KINGS COUNTY CLERK 06/29/2021 12:02 PM INDEX NO. 510844/2016
------
NYSCEF DOC.
u NO. 786 RECEIVED
RECEIVED NYSCEF:11/03/20?S
NYSCEF: 06/29/2021
NYSCEF DOC. NO. 1
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
------------------------------------X Index No.
GEORGE KALOIDIS,
Filed On:
Plaintiff(s),
Plaintiff designates
Queens County as the
place of trial pursuant
to CPLR 503
-against-
SUMMONS
STEVEN PAPPAS a/k/a STEVE PAPPAS
Defendant(s).
___________-------------------------X
TO THE ABOVE NAMED DEFENDANT(s) :
YOU ARE HEREBY SUMMONED to answer the complaint in this
action and to serve a copy of your answer, or, if the complaint
is not served with the summons, to serve a notice of appearance,
on Plaintiff's attorney within TWENTY (20) days after the
service of this summons, exclusive of the day of service, or if
service of this summons is made by any means other than by
personal delivery to you within the state, within THIRTY (30)
days after such service is complete. In the case of your failing
to appear or answer, judgment will be taken against you by
default for the relief demanded in the annexed complaint.
Dated: November 3, 2015
Kew Gardens, New York
Yours etc.,
Dustin B w n, Esq., P.C.
.v1fuÁtin Bowman, Esq.
ttorney for the Plaintiff
125-10 Queens Boulevard, Suite 218
Kew Gardens, New York 11415
Tel: 718-263-6800
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FILED: KINGS COUNTY CLERK 06/29/2021 12:02 PM INDEX NO. 510844/2016
NYSCEF DOC. NO. 786 RECEIVED
RECEIVED NYSCEF:
NYSCEF: 11/04/2015
06/29/2021
NYSCEF DOC. NO. 2
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
------------------------------------X Index No. 711428/2015
GEORGE KALOIDIS,
Plaintiff(s),
-against- AMENDED COMPLAINT
STEVEN PAPPAS a/k/a STEVE PAPPAS,
Defendant(s).
______------------------------------X
Plaintiff GEORGE KALOIDIS by and through its attorney
Dustin Bowman, Esq. PC, complaining of the Defendant(s), alleges
upon information and belief as follows:
1. That at all times hereinafter mentioned, the Plaintiff
was and is an individual residing in County of Queens, State of
| New York at 8800 Shore front Parkway, 5N, Rockaway Beach.
2. That at all times hereinafter mentioned, the Defendant
was and is an individual residing at in the County of New York,
62nd
State of New York at 300 East street, Apt 2704, New
York, NY 10065.
AS AND FOR A FIRST CAUSE OF ACTION
3. On or about July 1, 2003, Plaintiff loaned Fifty
Thousand dollars ($50,000.00) to Defendant who executed a
("18t
promissory note for Fifty Thousand dollars ($50,000.00)
Note") in favor of Plaintiff.
15t
4. Pursuant to the terms of the Note $50,000 plus
interest in currently due and payable from Defendant to
Plaintiff.
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FILED: KINGS COUNTY CLERK 06/29/2021 12:02 PM INDEX NO. 510844/2016
NYSCEF DOC. NO. 786 RECEIVED NYSCEF: 06/29/2021
18t
5. Defendant's failure to timely pay upon the Note is
18t
a material breach of the Note.
6. As a result of Defendant's material breach, Plaintiff
has been damaged in an amount to be determined by the Court, but
in no case less than Fifty Thousand dollars ($50,000.00) with
interest together with costs and attorney fees.
AS AND FOR A SECOND CAUSE OF ACTION
7. Plaintiff repeats and realleges each and every
"1" "6"
allegation contained in paragraphs through with the same
force and effect as if set forth at length herein.
8. On or about November 1, 2004, Plaintiff loaned One
Hundred Thousand dollars ($100,000.00) to Defendant who executed
a promissory note for One Hundred Thousand dollars ($100,000.00)
("2nd
Note") in favor of elaintiff.
2nd
9. Pursuant to the terms of the Note One Hundred
Thousand dollars ($100,000.00) plus interest in currently due
and payable from Defendant to Plaintiff.
2nd
10. Defendant's failure to timely pay upon the NOte is
2nd
a material breach of the NOte.
11. As a result of Defendant's material breach, Plaintiff
has been damaged in an amount to be determined by the Court, but
in no case less than One Hundred Thousand dollars ($100,000.00)
with interest together with costs and attorney fees.
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FILED: KINGS COUNTY CLERK 06/29/2021 12:02 PM INDEX NO. 510844/2016
NYSCEF DOC. NO. 786 RECEIVED NYSCEF: 06/29/2021
AS AND FOR A THIRD CAUSE OF ACTION
12. Plaintiff repeats and realleges each and every
"1" "11"
allegation contained in paragraphs through with the
same force and effect as if set forth at length herein.
13. On or about January 19, 2008, Plaintiff loaned Six
Hundred Thousand dollars ($600,000.00) to Defendant who executed
a promissory note for Six Hundred Thousand dollars ($600,000.00)
("3rd ("3rd
NOte") in faVOr Of Plaintiff Note"). On or about July
27, 2009, Plaintiff novated Two Hundred Thousand Dollars
3rd
($200,000.00) to the Note which was intended to include all
lSt 2nd
amounts due under the Note and note.
3rd
14. Pursuant to the terms of the Note, Eight Hundred
Thousand dollars ($800,000.00) plus interest in currently due
and payable from Defendant to Plaintiff.
3rd
15. Defendant's failure to timely pay upon the
d
a material breach of the 3 Note.
16. As a result of Defendant's material breach, Plaintiff
has been damaged in an amount to be determined by the Court, but
in no case less Eight Hundred Thousand dollars ($800,000.00)
with interest together with costs and attorney fees.
WHEREFORE, it is respectfully requested that an Order be made
and entered granting JUDGMENT as follows:
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FILED: KINGS COUNTY CLERK 06/29/2021 12:02 PM INDEX NO. 510844/2016
NYSCEF DOC. NO. 786 RECEIVED NYSCEF: 06/29/2021
a. Money judgment in favor of Plaintiff and against
Defendant in an amount of Fifty Thousand dollars ($50,000.00),
with interest together with costs and attorney fees; and
b. Money judgment in favor of Plaintiff and against
Defendant in an amount of One Hundred Thousand dollars
($100,000.00), with interest together with costs and attorney
fees; and
c. in favor of Plaintiff and against Defendant in an
amount of Eight Hundred Thousand dollars ($800,000.00), with
interest together with costs and attorney fees; and
d. Such further and additional relief as this Court deems
just and proper.
Dated: November 3, 2015
Kew Gardens, New York
Yours, etc.,
Dustin Bowman, Esq., P.C.
By: Dustin owman sq.
125 10 Queens Bo evard, Suite 218
Kew Gardens, N w York 11415
(718) 263 6800
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FILED: KINGS COUNTY CLERK 06/29/2021 12:02 PM INDEX NO. 510844/2016
NYSCEF DOC. NO. 786 RECEIVED NYSCEF: 06/29/2021
ATTORNEY CERTIFICATION
I, Dustin Bowman, hereby certify, under penalty of perjury,
and as an officer of the court, that to the best of my
knowledge, information and belief, formed after an inquiry
reasonably under the circumstances, the presentation of the
papers or the contentions herein are not frivolous as defined in
22 NYCRR Section 130-1.1(c).
Dated: November 3, 2015
Kew Gardens, New York
Dustin Bowman, Esq.
-6-
Preview
FILED: KINGS COUNTY CLERK 06/29/2021 12:02 PM INDEX NO. 510844/2016 NYSCEF DOC. NO. 786 RECEIVED NYSCEF: 06/29/2021 EXHIBIT Q FILED: KINGS COUNTY CLERK 06/29/2021 12:02 PM INDEX NO. 510844/2016 ------ NYSCEF DOC. u NO. 786 RECEIVED RECEIVED NYSCEF:11/03/20?S NYSCEF: 06/29/2021 NYSCEF DOC. NO. 1 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS ------------------------------------X Index No. GEORGE KALOIDIS, Filed On: Plaintiff(s), Plaintiff designates Queens County as the place of trial pursuant to CPLR 503 -against- SUMMONS STEVEN PAPPAS a/k/a STEVE PAPPAS Defendant(s). ___________-------------------------X TO THE ABOVE NAMED DEFENDANT(s) : YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a copy of your answer, or, if the complaint is not served with the summons, to serve a notice of appearance, on Plaintiff's attorney within TWENTY (20) days after the service of this summons, exclusive of the day of service, or if service of this summons is made by any means other than by personal delivery to you within the state, within THIRTY (30) days after such service is complete. In the case of your failing to appear or answer, judgment will be taken against you by default for the relief demanded in the annexed complaint. Dated: November 3, 2015 Kew Gardens, New York Yours etc., Dustin B w n, Esq., P.C. .v1fuÁtin Bowman, Esq. ttorney for the Plaintiff 125-10 Queens Boulevard, Suite 218 Kew Gardens, New York 11415 Tel: 718-263-6800 -1- FILED: KINGS COUNTY CLERK 06/29/2021 12:02 PM INDEX NO. 510844/2016 NYSCEF DOC. NO. 786 RECEIVED RECEIVED NYSCEF: NYSCEF: 11/04/2015 06/29/2021 NYSCEF DOC. NO. 2 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS ------------------------------------X Index No. 711428/2015 GEORGE KALOIDIS, Plaintiff(s), -against- AMENDED COMPLAINT STEVEN PAPPAS a/k/a STEVE PAPPAS, Defendant(s). ______------------------------------X Plaintiff GEORGE KALOIDIS by and through its attorney Dustin Bowman, Esq. PC, complaining of the Defendant(s), alleges upon information and belief as follows: 1. That at all times hereinafter mentioned, the Plaintiff was and is an individual residing in County of Queens, State of | New York at 8800 Shore front Parkway, 5N, Rockaway Beach. 2. That at all times hereinafter mentioned, the Defendant was and is an individual residing at in the County of New York, 62nd State of New York at 300 East street, Apt 2704, New York, NY 10065. AS AND FOR A FIRST CAUSE OF ACTION 3. On or about July 1, 2003, Plaintiff loaned Fifty Thousand dollars ($50,000.00) to Defendant who executed a ("18t promissory note for Fifty Thousand dollars ($50,000.00) Note") in favor of Plaintiff. 15t 4. Pursuant to the terms of the Note $50,000 plus interest in currently due and payable from Defendant to Plaintiff. -2- FILED: KINGS COUNTY CLERK 06/29/2021 12:02 PM INDEX NO. 510844/2016 NYSCEF DOC. NO. 786 RECEIVED NYSCEF: 06/29/2021 18t 5. Defendant's failure to timely pay upon the Note is 18t a material breach of the Note. 6. As a result of Defendant's material breach, Plaintiff has been damaged in an amount to be determined by the Court, but in no case less than Fifty Thousand dollars ($50,000.00) with interest together with costs and attorney fees. AS AND FOR A SECOND CAUSE OF ACTION 7. Plaintiff repeats and realleges each and every "1" "6" allegation contained in paragraphs through with the same force and effect as if set forth at length herein. 8. On or about November 1, 2004, Plaintiff loaned One Hundred Thousand dollars ($100,000.00) to Defendant who executed a promissory note for One Hundred Thousand dollars ($100,000.00) ("2nd Note") in favor of elaintiff. 2nd 9. Pursuant to the terms of the Note One Hundred Thousand dollars ($100,000.00) plus interest in currently due and payable from Defendant to Plaintiff. 2nd 10. Defendant's failure to timely pay upon the NOte is 2nd a material breach of the NOte. 11. As a result of Defendant's material breach, Plaintiff has been damaged in an amount to be determined by the Court, but in no case less than One Hundred Thousand dollars ($100,000.00) with interest together with costs and attorney fees. -3- FILED: KINGS COUNTY CLERK 06/29/2021 12:02 PM INDEX NO. 510844/2016 NYSCEF DOC. NO. 786 RECEIVED NYSCEF: 06/29/2021 AS AND FOR A THIRD CAUSE OF ACTION 12. Plaintiff repeats and realleges each and every "1" "11" allegation contained in paragraphs through with the same force and effect as if set forth at length herein. 13. On or about January 19, 2008, Plaintiff loaned Six Hundred Thousand dollars ($600,000.00) to Defendant who executed a promissory note for Six Hundred Thousand dollars ($600,000.00) ("3rd ("3rd NOte") in faVOr Of Plaintiff Note"). On or about July 27, 2009, Plaintiff novated Two Hundred Thousand Dollars 3rd ($200,000.00) to the Note which was intended to include all lSt 2nd amounts due under the Note and note. 3rd 14. Pursuant to the terms of the Note, Eight Hundred Thousand dollars ($800,000.00) plus interest in currently due and payable from Defendant to Plaintiff. 3rd 15. Defendant's failure to timely pay upon the d a material breach of the 3 Note. 16. As a result of Defendant's material breach, Plaintiff has been damaged in an amount to be determined by the Court, but in no case less Eight Hundred Thousand dollars ($800,000.00) with interest together with costs and attorney fees. WHEREFORE, it is respectfully requested that an Order be made and entered granting JUDGMENT as follows: -4- FILED: KINGS COUNTY CLERK 06/29/2021 12:02 PM INDEX NO. 510844/2016 NYSCEF DOC. NO. 786 RECEIVED NYSCEF: 06/29/2021 a. Money judgment in favor of Plaintiff and against Defendant in an amount of Fifty Thousand dollars ($50,000.00), with interest together with costs and attorney fees; and b. Money judgment in favor of Plaintiff and against Defendant in an amount of One Hundred Thousand dollars ($100,000.00), with interest together with costs and attorney fees; and c. in favor of Plaintiff and against Defendant in an amount of Eight Hundred Thousand dollars ($800,000.00), with interest together with costs and attorney fees; and d. Such further and additional relief as this Court deems just and proper. Dated: November 3, 2015 Kew Gardens, New York Yours, etc., Dustin Bowman, Esq., P.C. By: Dustin owman sq. 125 10 Queens Bo evard, Suite 218 Kew Gardens, N w York 11415 (718) 263 6800 -5- FILED: KINGS COUNTY CLERK 06/29/2021 12:02 PM INDEX NO. 510844/2016 NYSCEF DOC. NO. 786 RECEIVED NYSCEF: 06/29/2021 ATTORNEY CERTIFICATION I, Dustin Bowman, hereby certify, under penalty of perjury, and as an officer of the court, that to the best of my knowledge, information and belief, formed after an inquiry reasonably under the circumstances, the presentation of the papers or the contentions herein are not frivolous as defined in 22 NYCRR Section 130-1.1(c). Dated: November 3, 2015 Kew Gardens, New York Dustin Bowman, Esq. -6-