Preview
FILED: ERIE COUNTY CLERK 04/06/2022 04:31 PM INDEX NO. 816576/2020
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 04/06/2022
STATEOFNEW YORK
SUPREME COURT : COUNTY OF ERIE
RICHARD LIPPES; RICHARD J. LIPPES; LIPPES & LIPPES,
Index No. 816576/2020
Plaintiffs,
-vs-
KEY BANK,
Defendant.
STATE OF NEW YORK
SUPREME COURT : COUNTY OF ERIE
LAWYERS FUNDING GROUP, LLC,
Index No. 802329/2020
Plaintiff
-vs-
RICHARD J. LIPPES, ESQ.,
RICHARD J. LIPPES & ASSOCIATES,
A/K/A, LIPPES & LIPPES,
Defendants.
CONFIDENTIAL SETTLEMENT AGREEMENT
This Confidential Settlement Agreement ("Agreement") is entered into as of August 6,
2021 (the "Effective Date"), by and between RICHARD J. LIPPES, on behalf of himself,
RICHARD J. LIPPES & ASSOCIATES, A/K/A, LIPPES & LIPPES ("LIPPES"), and
KEYBANK NATIONAL ASSOCIATION , ("KEYBANK"), and LAWYERS FUNDING
GROUP, LLC ("LFG").
I. RECITALS.
Whereas:
1. RICHARD J. LIPPES, ESQ. is an attorney licensed to practice law in the State of New
York with principal offices located at 1109 Delaware Ave., Buffalo, NY, NY 14209.
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FILED: ERIE COUNTY CLERK 04/06/2022 04:31 PM INDEX NO. 816576/2020
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 04/06/2022
2. LAWYERS FUNDING GROUP LLC is a Pennsylvania Limited Liability Company with
offices located at 2 Penn Center, Suite 1700, 1500 JFK Blvd., Philadelphia, PA 19102.
3. KEYBANK is a national banking association with its principal place of business at 127
Public Square, Cleveland Ohio 44114 and is authorized to do business in the State of New
York.
4. LAWYERS FUNDING GROUP LLC is a Judgment creditor with a Judgment against
Richard J. Lippes in the amount of $121,500.00 plus costs filed it the action, LAWYERS
FUNDING -vs- RICHARD J. RICHARD J.
GROUP, LLC, Plaintiff LIPPES, ESQ.,
LIPPES & ASSOCIATES, A/K/A, LIPPES & LIPPES, Defendant, Erie County Supreme
Court Index No. 802329/2020, filed on August 4, 2020.
5. Pursuant to said Judgment, LFG served an Information Subpoena and Restraining Notice
upon KEYBANK and thereby restrained an account maintained at KEYBANK by Richard
J. Lipppes, bearing Account No. 327043022315.
6. Richard J. Lippes agrees to pay to LAWYERS FUNDING GROUP, LLC the amount of
$125,000.00 on or before October 31, 2021. Said funds will be part of the proceeds of sale
of the Lippes home situate at 7 NY SBL No. 79.07-
family Audley End, Amherst, 14226,
1-76, and owned by his wife, Sharon R. Lippes. In the event the closing is delayed past
October 31, 2021, Richard J. Lippes agrees to pay interest on the $125,000.00 settlement
amount at 5.5% per annum, or $18.84 per day.
7. LFG agrees to accept the payment from Lippes in full satisfaction of the Judgment against
him and to execute and file a Satisfaction of Judgment upon payment.
8. LFG, in consideration for the above, agrees to release the restraint of KEYBANK Account
No. 327043022315, within seven (7) days of the execution of this agreement by allparties.
9. The attorneys for all parties shall sign and file a Stipulation of Discontinuance, with
Prejudice, in the action brought by Richard J. Lippes against KEYBANK, bearing Erie
County Supreme Court Index No. 816576/2020, simultaneously with the execution of this
agreement. .
10. This document shall be kept confidential by the parties and their attorneys.
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FILED: ERIE COUNTY CLERK 04/06/2022 04:31 PM INDEX NO. 816576/2020
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 04/06/2022
IN WITNESS WHEREOF, the parties have executed this Agreement on the day of August, 2021.
RICHARD J. LIP S
By:
KEYBANK NATIONAL ASSOCIATION
By:
LAWYERS FUNDING GROUP, LLC
By:
SHARON R. LIPPES, AS GUARANTOR
By:
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Preview
FILED: ERIE COUNTY CLERK 04/06/2022 04:31 PM INDEX NO. 816576/2020 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 04/06/2022 STATEOFNEW YORK SUPREME COURT : COUNTY OF ERIE RICHARD LIPPES; RICHARD J. LIPPES; LIPPES & LIPPES, Index No. 816576/2020 Plaintiffs, -vs- KEY BANK, Defendant. STATE OF NEW YORK SUPREME COURT : COUNTY OF ERIE LAWYERS FUNDING GROUP, LLC, Index No. 802329/2020 Plaintiff -vs- RICHARD J. LIPPES, ESQ., RICHARD J. LIPPES & ASSOCIATES, A/K/A, LIPPES & LIPPES, Defendants. CONFIDENTIAL SETTLEMENT AGREEMENT This Confidential Settlement Agreement ("Agreement") is entered into as of August 6, 2021 (the "Effective Date"), by and between RICHARD J. LIPPES, on behalf of himself, RICHARD J. LIPPES & ASSOCIATES, A/K/A, LIPPES & LIPPES ("LIPPES"), and KEYBANK NATIONAL ASSOCIATION , ("KEYBANK"), and LAWYERS FUNDING GROUP, LLC ("LFG"). I. RECITALS. Whereas: 1. RICHARD J. LIPPES, ESQ. is an attorney licensed to practice law in the State of New York with principal offices located at 1109 Delaware Ave., Buffalo, NY, NY 14209. 1 FILED: ERIE COUNTY CLERK 04/06/2022 04:31 PM INDEX NO. 816576/2020 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 04/06/2022 2. LAWYERS FUNDING GROUP LLC is a Pennsylvania Limited Liability Company with offices located at 2 Penn Center, Suite 1700, 1500 JFK Blvd., Philadelphia, PA 19102. 3. KEYBANK is a national banking association with its principal place of business at 127 Public Square, Cleveland Ohio 44114 and is authorized to do business in the State of New York. 4. LAWYERS FUNDING GROUP LLC is a Judgment creditor with a Judgment against Richard J. Lippes in the amount of $121,500.00 plus costs filed it the action, LAWYERS FUNDING -vs- RICHARD J. RICHARD J. GROUP, LLC, Plaintiff LIPPES, ESQ., LIPPES & ASSOCIATES, A/K/A, LIPPES & LIPPES, Defendant, Erie County Supreme Court Index No. 802329/2020, filed on August 4, 2020. 5. Pursuant to said Judgment, LFG served an Information Subpoena and Restraining Notice upon KEYBANK and thereby restrained an account maintained at KEYBANK by Richard J. Lipppes, bearing Account No. 327043022315. 6. Richard J. Lippes agrees to pay to LAWYERS FUNDING GROUP, LLC the amount of $125,000.00 on or before October 31, 2021. Said funds will be part of the proceeds of sale of the Lippes home situate at 7 NY SBL No. 79.07- family Audley End, Amherst, 14226, 1-76, and owned by his wife, Sharon R. Lippes. In the event the closing is delayed past October 31, 2021, Richard J. Lippes agrees to pay interest on the $125,000.00 settlement amount at 5.5% per annum, or $18.84 per day. 7. LFG agrees to accept the payment from Lippes in full satisfaction of the Judgment against him and to execute and file a Satisfaction of Judgment upon payment. 8. LFG, in consideration for the above, agrees to release the restraint of KEYBANK Account No. 327043022315, within seven (7) days of the execution of this agreement by allparties. 9. The attorneys for all parties shall sign and file a Stipulation of Discontinuance, with Prejudice, in the action brought by Richard J. Lippes against KEYBANK, bearing Erie County Supreme Court Index No. 816576/2020, simultaneously with the execution of this agreement. . 10. This document shall be kept confidential by the parties and their attorneys. 2 FILED: ERIE COUNTY CLERK 04/06/2022 04:31 PM INDEX NO. 816576/2020 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 04/06/2022 IN WITNESS WHEREOF, the parties have executed this Agreement on the day of August, 2021. RICHARD J. LIP S By: KEYBANK NATIONAL ASSOCIATION By: LAWYERS FUNDING GROUP, LLC By: SHARON R. LIPPES, AS GUARANTOR By: 3