On March 30, 2022 a
No Value
was filed
involving a dispute between
Unique Funding Solutions Llc,
and
Arete Rehabilitation, Inc.,
Janet Leah Mahoney,
for Commercial - Contract
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 05/05/2022 10:06 AM INDEX NO. 509227/2022
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 05/05/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
UNIQUE FUNDING SOLUTIONS LLC, Index No.: 509227/2022
Plaintiff,
vs. NON-MILITARY
AFFIRMATION
ARETE REHABILITATION, INC. AND
JANET LEAH MAHONEY,
Defendants.
STATE OF NEW YORK )
)
COUNTY OF NASSAU )
Yonatan Klestzick, an attorney admitted to practice law in the State of New York, affirms
the following under the penalties of perjury:
1. I am over the age of 18 years, am not a party to this action, and am a resident of the State
of New York.
2. As an attorney for UNIQUE FUNDING SOLUTIONS LLC (“Plaintiff”), I made an
investigation to determine whether or not JANET LEAH MAHONEY is in military service.
3. I provided the Department of Defense, Defense Manpower Data Center, with pertinent
information about JANET LEAH MAHONEY, including said Defendant’s name and date of
birth or social security number, that was provided to me by Plaintiff in order that a military
investigation be conducted.
4. Based upon the response I received from the Department of Defense, Defense Manpower
Data Center, a printout of which is annexed hereto, I believe that JANET LEAH MAHONEY is
not in military service.
1 of 4
FILED: KINGS COUNTY CLERK 05/05/2022 10:06 AM INDEX NO. 509227/2022
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 05/05/2022
Dated: Nassau County, New York
May 5, 2022
LIEBERMAN AND KLESTZICK, LLP
By: ________________________
Yonatan Klestzick, Esq.
Attorneys for Plaintiff
71 S Central Avenue
Valley Stream NY 11580
P: (516) 900-6720
2 of 4
FILED: KINGS COUNTY CLERK 05/05/2022 10:06 AM INDEX NO. 509227/2022
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 05/05/2022
WORD COUNT CERTIFICATION
I hereby certify pursuant to part 202.8-b of the Uniform Civil Rules for the Supreme Court
& the County Court that this document according to the word count tool on Microsoft Word, the
total number of words in this document is 153, consistent with the rule that (i) affidavits,
affirmations, briefs and memoranda of law in chief be limited to 7,000 words each; (ii) reply
affidavits, affirmations, and memoranda be no more than 4,200 words, and do not contain any
arguments that do not respond or relate to those made in the memoranda in chief.
Dated: May 5, 2022 Respectfully submitted,
Nassau County, New York
By: ________________________
Yonatan Klestzick, Esq.
Lieberman and Klestzick, LLP
Attorneys for Plaintiff
71 S Central Avenue
Valley Stream NY 11580
P: 516-900-6720
Email: Yklestzick@landklegal.com
3 of 4
FILED: KINGS COUNTY CLERK 05/05/2022 10:06 AM INDEX NO. 509227/2022
NYSCEF DOC. NO. 10 RECEIVED NYSCEF:
Results 05/05/2022
asor : May-05-2022
0957:33AM
Department of Defense Manpower Data Center
SCRA5.12
Status Report
Pursuant to Servicemembers Civil Relief Act
SSN:
Birth Date:
Last Name: MAHONEY
First Name: JANET
Middle Name: LEAH
Status As Of: May-05-2022
Certificate ID: HD7M314BKYY33Z2
OnAcUveDutyOnAcUveDulySims Dale
ActiveDutyStartDate ActiveDutyEndDale Stalus ServiceComponent
NA NA No NA
ThisresponseregectsUseindividuals'activeduly statusbasedontheActiveDutyStatusDate
LeltAcliveDutyWithin367DaysorAcliveDutyStatusDale
ActiveDutyStartDale ActiveDutyEndDate Status ServiceComponent
NA NA No NA
ThisresparisereAectswhere8teindividualleftactivedutystatuswitiin 367daysprecedrigtheActiveDutyStatusDate
TheMemberor His/HerUnitWasNotiHedora FutureCan-Upto ActiveDulyonActiveDutyStalusDale
OrderNotiAcaHon
StartDale OrderNotHication
EndDale Stalus ServiceComponent
NA NA No NA
Thisresponsereflectswhethertheindividualor his/herunithasreceivedearlynolilicationto reportfor activeduly
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
Michael V. Sorrento, Director
Department of Defense - Manpower Data Center
400 Gigling Rd.
Seaside, CA 93955
4 of 4
Document Filed Date
May 05, 2022
Case Filing Date
March 30, 2022
Category
Commercial - Contract
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FILED: KINGS COUNTY CLERK 05/05/2022 10:06 AM INDEX NO. 509227/2022 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 05/05/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS UNIQUE FUNDING SOLUTIONS LLC, Index No.: 509227/2022 Plaintiff, vs. NON-MILITARY AFFIRMATION ARETE REHABILITATION, INC. AND JANET LEAH MAHONEY, Defendants. STATE OF NEW YORK ) ) COUNTY OF NASSAU ) Yonatan Klestzick, an attorney admitted to practice law in the State of New York, affirms the following under the penalties of perjury: 1. I am over the age of 18 years, am not a party to this action, and am a resident of the State of New York. 2. As an attorney for UNIQUE FUNDING SOLUTIONS LLC (“Plaintiff”), I made an investigation to determine whether or not JANET LEAH MAHONEY is in military service. 3. I provided the Department of Defense, Defense Manpower Data Center, with pertinent information about JANET LEAH MAHONEY, including said Defendant’s name and date of birth or social security number, that was provided to me by Plaintiff in order that a military investigation be conducted. 4. Based upon the response I received from the Department of Defense, Defense Manpower Data Center, a printout of which is annexed hereto, I believe that JANET LEAH MAHONEY is not in military service. 1 of 4 FILED: KINGS COUNTY CLERK 05/05/2022 10:06 AM INDEX NO. 509227/2022 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 05/05/2022 Dated: Nassau County, New York May 5, 2022 LIEBERMAN AND KLESTZICK, LLP By: ________________________ Yonatan Klestzick, Esq. Attorneys for Plaintiff 71 S Central Avenue Valley Stream NY 11580 P: (516) 900-6720 2 of 4 FILED: KINGS COUNTY CLERK 05/05/2022 10:06 AM INDEX NO. 509227/2022 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 05/05/2022 WORD COUNT CERTIFICATION I hereby certify pursuant to part 202.8-b of the Uniform Civil Rules for the Supreme Court & the County Court that this document according to the word count tool on Microsoft Word, the total number of words in this document is 153, consistent with the rule that (i) affidavits, affirmations, briefs and memoranda of law in chief be limited to 7,000 words each; (ii) reply affidavits, affirmations, and memoranda be no more than 4,200 words, and do not contain any arguments that do not respond or relate to those made in the memoranda in chief. Dated: May 5, 2022 Respectfully submitted, Nassau County, New York By: ________________________ Yonatan Klestzick, Esq. Lieberman and Klestzick, LLP Attorneys for Plaintiff 71 S Central Avenue Valley Stream NY 11580 P: 516-900-6720 Email: Yklestzick@landklegal.com 3 of 4 FILED: KINGS COUNTY CLERK 05/05/2022 10:06 AM INDEX NO. 509227/2022 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: Results 05/05/2022 asor : May-05-2022 0957:33AM Department of Defense Manpower Data Center SCRA5.12 Status Report Pursuant to Servicemembers Civil Relief Act SSN: Birth Date: Last Name: MAHONEY First Name: JANET Middle Name: LEAH Status As Of: May-05-2022 Certificate ID: HD7M314BKYY33Z2 OnAcUveDutyOnAcUveDulySims Dale ActiveDutyStartDate ActiveDutyEndDale Stalus ServiceComponent NA NA No NA ThisresponseregectsUseindividuals'activeduly statusbasedontheActiveDutyStatusDate LeltAcliveDutyWithin367DaysorAcliveDutyStatusDale ActiveDutyStartDale ActiveDutyEndDate Status ServiceComponent NA NA No NA ThisresparisereAectswhere8teindividualleftactivedutystatuswitiin 367daysprecedrigtheActiveDutyStatusDate TheMemberor His/HerUnitWasNotiHedora FutureCan-Upto ActiveDulyonActiveDutyStalusDale OrderNotiAcaHon StartDale OrderNotHication EndDale Stalus ServiceComponent NA NA No NA Thisresponsereflectswhethertheindividualor his/herunithasreceivedearlynolilicationto reportfor activeduly Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Michael V. Sorrento, Director Department of Defense - Manpower Data Center 400 Gigling Rd. Seaside, CA 93955 4 of 4