On June 22, 2016 a
Exhibit,Appendix
was filed
involving a dispute between
Marcelo Lema,
and
Pan Link Construction, Inc,
Ssw Realty Llc,
for Torts - Other (Labor Law)
in the District Court of Queens County.
Preview
FILED: QUEENS COUNTY
COUNTY CLERK
CLERK 12/15/2017
08/09/2016 06:48
04:25 PM INDEX
INDEX NO.
NO. 707343/2016
707343/2016
FILED: QUEENS PM|
NYSCEF
NYSCEF DOC.
DOC. NO.
NO. 326 RECEIVED
RECEIVED NYSCEF:
NYSCEF: 12/15/2017
08/09/2016
Index # 707343/2016
Purchased/Filed: June 22, 2016
Attorney(s)
AFFIDAVIT OF SERVICE - SECRETARY OF STATE
State of New York Supreme Court Queens County
Marcelo Lema
Plaintiff
against
Pan Link Construction Inc et at Defendant
STATE OF NEW YORK )
.) DESCRIPTION OF PERSON SERVED: Approx. Age: 55 Yrs.
COUNTYOFALBANY )SS
CITY OF ALBANY 5'
) Weight: 120 Lbs. Height: Sex: Female Color of skin: White
Hair color: Brown Other:
Sean Warner , being duly sworn, deposes and says: deponent isover
the age of eighteen (18) years; that on June 23, 2016 , at 11:34 AM , atthe officeof the
Secretary of State of the State of New York located at 99 Washington Ave, 6th Fi,Albany, New York deponent served
Summons & Verified Complaint with Noticeof Commencement ofAction Subject toMandatory ElectronicFiling
on
Pan Link Construction Inc
I
the Defendant in thisaction, by delivering to and leaving with Sue Zouky
AUTHORIZED AGENT in the Office of the Secretary of State, of the State of New York, personally at the
Office of the Secretary of State of the State of New York, two (2) true copies thereof and that at the time of
making such service, deponent paid said Secretary of State a fee of 40 dollars; That said service
was made pursuant to Section BUSINESS CORPORATION LAW §306.
Deponent further says that deponent knew the person so served as aforesaid to be the agent in the Office
of the Secretary of State of the State of New York, duly authorized to accept such service on behalf of said
defendant.
Sworn to before me on this
23rd da
_day of June 2016
FAITH COZ
Sean Warner
NOTARY PUBLIC, State rk
No. 01C06158874,A;bany County Invoice•Work Order #1613600
Commission Expires Jan 8, 2019
Attorney File # Lema
1 of 1
FILED: QUEENS COUNTY CLERK 12/15/2017 06:48 PM INDEX NO. 707343/2016
NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 12/15/2017
RIMLAND&ASSOCIATES
ATTORNEYS AT LAW
225 BROADWAY, SUITE 1606
NEW YORK,NY 10007
TEL: (212)374-0680
FAX: (212)374-0681
EDWARDRIMLAND WWW.rimlandlaw.com
DIANADELAGUERRA
ED@RIMLANDLAW.COM DGUERRA@RIMLANDLAW.COM
DAVIDFRIEDMAN CATALINARIASCOS
DFRIEDMAN@RIMLANDLAW.COM
CMRIASCOS@RIMLANDLAW,COM
GLENEAHLERS
GAHLERS@RIMLANDLAW,COM PARALEGALS
ROBERTELAN
JASONPARIS
HERNAN CACERES
OF COUNSEL
July 10, 2017
VIA CERTIFIED MAIL, RETURN RECEIPT
& REGULAR MAIL
PAN LINK CONSTRUCTION, I INC.
29 Beach Road
Great Neck, NY 11023
Re: Marcelo Lema
D/Acc: June 18, 2015
Dear Sir/Madam:
Please be advised that this office represent plaintiff Marcelo
Lema in a lawsuit commenced against you.
Pursuant to CPLR Section 3215(g) (4) (i) and Business
Corporation Law Section 306(b) , you are HEREBY ON NOTICE that
service upon you has been made by virtue of the Secretary of State,
and a default judgment will be sought against you.
Further pursuant to the above-referenced provisions, enclosed
please find an additional copy of the Summons and Complaint in this
matter.
Ve truly yours,
ward Rimland
ER/dg
Encl.
l
FILED: QUEENS COUNTY CLERK 12/15/2017 06:48 PM INDEX NO. 707343/2016
NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 12/15/2017
n A. Signatur
Complete items1, 2, and 3.
n Print
ybur name and address on thereverse
X O Addressee
so thatwe can returnthe cardto you. .. .
n back of the ted Name) C. Date of Delivery
Attach thiscardto the mailpiece,
if space
or on the front permits.
1. Article Addressed to: O Yes
D. Is delivery address different from item 1?
If YES, enter delivery address below:
O No
)~Pm LKa< '~<~®C~Ci frnC'.
g;~>', IP"
Zci
3. Service Type O PriorityMallExpress®
O AdultSignature Mail™
O Registered
AdultSignatureRestrictedDelivery
0 Registered
MailRestrictec
O CertifiedMail® Delivery
9590 9401 00M 5168 4885 05 0 ReturnReceiptfor
0 certifiedMailRestrictedDelivery
O Collecton Delivery Merchandise
a w _o
¯ O SignatureConfirmation™
Dollectan DeliveryRestrictedDelivery
InsuredMail . O SignatureConfirmation
7015 0b40 0007 b391 2698 RestrictedDelivery
__......_........
.nsured
insuredMailRestrictedDelivery
(over$500)
PS Form 3811, April2015 PSN 7530-02-000-9053 Domestic Return Receipt
Document Filed Date
December 15, 2017
Case Filing Date
June 22, 2016
Category
Torts - Other (Labor Law)
Status
Disposed-Court Date/Application Pending
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FILED: QUEENS COUNTY COUNTY CLERK CLERK 12/15/2017 08/09/2016 06:48 04:25 PM INDEX INDEX NO. NO. 707343/2016 707343/2016 FILED: QUEENS PM| NYSCEF NYSCEF DOC. DOC. NO. NO. 326 RECEIVED RECEIVED NYSCEF: NYSCEF: 12/15/2017 08/09/2016 Index # 707343/2016 Purchased/Filed: June 22, 2016 Attorney(s) AFFIDAVIT OF SERVICE - SECRETARY OF STATE State of New York Supreme Court Queens County Marcelo Lema Plaintiff against Pan Link Construction Inc et at Defendant STATE OF NEW YORK ) .) DESCRIPTION OF PERSON SERVED: Approx. Age: 55 Yrs. COUNTYOFALBANY )SS CITY OF ALBANY 5' ) Weight: 120 Lbs. Height: Sex: Female Color of skin: White Hair color: Brown Other: Sean Warner , being duly sworn, deposes and says: deponent isover the age of eighteen (18) years; that on June 23, 2016 , at 11:34 AM , atthe officeof the Secretary of State of the State of New York located at 99 Washington Ave, 6th Fi,Albany, New York deponent served Summons & Verified Complaint with Noticeof Commencement ofAction Subject toMandatory ElectronicFiling on Pan Link Construction Inc I the Defendant in thisaction, by delivering to and leaving with Sue Zouky AUTHORIZED AGENT in the Office of the Secretary of State, of the State of New York, personally at the Office of the Secretary of State of the State of New York, two (2) true copies thereof and that at the time of making such service, deponent paid said Secretary of State a fee of 40 dollars; That said service was made pursuant to Section BUSINESS CORPORATION LAW §306. Deponent further says that deponent knew the person so served as aforesaid to be the agent in the Office of the Secretary of State of the State of New York, duly authorized to accept such service on behalf of said defendant. Sworn to before me on this 23rd da _day of June 2016 FAITH COZ Sean Warner NOTARY PUBLIC, State rk No. 01C06158874,A;bany County Invoice•Work Order #1613600 Commission Expires Jan 8, 2019 Attorney File # Lema 1 of 1 FILED: QUEENS COUNTY CLERK 12/15/2017 06:48 PM INDEX NO. 707343/2016 NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 12/15/2017 RIMLAND&ASSOCIATES ATTORNEYS AT LAW 225 BROADWAY, SUITE 1606 NEW YORK,NY 10007 TEL: (212)374-0680 FAX: (212)374-0681 EDWARDRIMLAND WWW.rimlandlaw.com DIANADELAGUERRA ED@RIMLANDLAW.COM DGUERRA@RIMLANDLAW.COM DAVIDFRIEDMAN CATALINARIASCOS DFRIEDMAN@RIMLANDLAW.COM CMRIASCOS@RIMLANDLAW,COM GLENEAHLERS GAHLERS@RIMLANDLAW,COM PARALEGALS ROBERTELAN JASONPARIS HERNAN CACERES OF COUNSEL July 10, 2017 VIA CERTIFIED MAIL, RETURN RECEIPT & REGULAR MAIL PAN LINK CONSTRUCTION, I INC. 29 Beach Road Great Neck, NY 11023 Re: Marcelo Lema D/Acc: June 18, 2015 Dear Sir/Madam: Please be advised that this office represent plaintiff Marcelo Lema in a lawsuit commenced against you. Pursuant to CPLR Section 3215(g) (4) (i) and Business Corporation Law Section 306(b) , you are HEREBY ON NOTICE that service upon you has been made by virtue of the Secretary of State, and a default judgment will be sought against you. Further pursuant to the above-referenced provisions, enclosed please find an additional copy of the Summons and Complaint in this matter. Ve truly yours, ward Rimland ER/dg Encl. l FILED: QUEENS COUNTY CLERK 12/15/2017 06:48 PM INDEX NO. 707343/2016 NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 12/15/2017 n A. Signatur Complete items1, 2, and 3. n Print ybur name and address on thereverse X O Addressee so thatwe can returnthe cardto you. .. . n back of the ted Name) C. Date of Delivery Attach thiscardto the mailpiece, if space or on the front permits. 1. Article Addressed to: O Yes D. Is delivery address different from item 1? If YES, enter delivery address below: O No )~Pm LKa< '~<~®C~Ci frnC'. g;~>', IP" Zci 3. Service Type O PriorityMallExpress® O AdultSignature Mail™ O Registered AdultSignatureRestrictedDelivery 0 Registered MailRestrictec O CertifiedMail® Delivery 9590 9401 00M 5168 4885 05 0 ReturnReceiptfor 0 certifiedMailRestrictedDelivery O Collecton Delivery Merchandise a w _o ¯ O SignatureConfirmation™ Dollectan DeliveryRestrictedDelivery InsuredMail . O SignatureConfirmation 7015 0b40 0007 b391 2698 RestrictedDelivery __......_........ .nsured insuredMailRestrictedDelivery (over$500) PS Form 3811, April2015 PSN 7530-02-000-9053 Domestic Return Receipt