Preview
FILED: MONROE COUNTY CLERK 10/14/2022 11:29 AM INDEX NO. E2020008624
NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 10/14/2022
MONROE COUNTY CLERK’S OFFICE THIS IS NOT A BILL. THIS IS YOUR RECEIPT.
Receipt #
Book Page
Return To: No. Pages: 7
YELENA SHAROVA
147 PRINCE STREET, 4TH FLOOR Instrument: AFFIRMATION
BROOKLYN, NY 11201
Control #: Unrecorded #9100302
Index #: E2020008624
Date:
Shanbhag, Ramdas Time:
Shanbhag, Ramdas
Trinidad, Maria
Jen Len, LLC
Jen Len 401 K Plan FBO Maria Trinidad
Jen Len, LLC, Revocable Living Trust
Equity Trust Company, Custodian, FBO, Maria Trinidad
Total Fees Paid: $0.00
Employee:
State of New York
MONROE COUNTY CLERK’S OFFICE
WARNING – THIS SHEET CONSTITUTES THE CLERKS
ENDORSEMENT, REQUIRED BY SECTION 317-a(5) &
SECTION 319 OF THE REAL PROPERTY LAW OF THE
STATE OF NEW YORK. DO NOT DETACH OR REMOVE.
JAMIE ROMEO
MONROE COUNTY CLERK
1 of 7
FILED: MONROE COUNTY CLERK 10/14/2022 11:29 AM INDEX NO. E2020008624
NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 10/14/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF MONROE
---------------------------------------------------------------------x
RAMDAS SHANBHAG and Index No.: E2020008624
RAMDAS SHANBHAG as Trustee for the
RAMDAS SHANBHAG TRUST,
Plaintiff,
-against- NYCRR § 202.7(f)
NOTICE AFFIRMATION
MARIA TRINIDAD;
JENLEN, LLC;
JENLEN 401K PLAN FBO MARIA TRINIDAD;
JENLEN, LLC, REVOCABLE LIVING TRUST;
EQUITY TRUST COMPANY, CUSTODIAN, FBO
MARIA TRINIDAD;
LIMA CHARLIE, LLC;
METRO CITY BANK;
LYONS NATIONAL BANK;
RADNAGE PROPERTY, LLC, and
“JOHN DOE” and “MARY DOE”, said names being
fictitious, parties intended being possible tenants or
occupants of premises, and corporations, other
entities or persons who claim, or may claim,
a lien against the premises,
Defendants.
--------------------------------------------------------------------X
CHARLES W. MARINO, ESQ., an attorney duly admitted to practice law in the State of
New York affirms the truth of the following under the penalties of perjury pursuant to CPLR §
2106:
1. I am a member of the Sharova Law Firm, attorneys for the Defendants JENLEN, LLC;
JENLEN 401K PLAN FBO MARIA TRINIDAD; JENLEN, LLC, REVOCABLE LIVING
TRUST and EQUITY TRUST COMPANY, CUSTODIAN, FBO MARIA TRINIDAD
(collectively “Defendants Trinidad Entities”), and as such am fully familiar with the facts,
proceedings and circumstances herein.
2 of 7
FILED: MONROE COUNTY CLERK 10/14/2022 11:29 AM INDEX NO. E2020008624
NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 10/14/2022
2. This matter is brought before the Court by way of Order to Show Cause as procedurally we
are seeking a preliminary injunction pursuant to CPLR § 6301.
3. On October 13, 2022 my office served notification via electronic email to the below listed
Plaintiff’s counsel, Defendants Lima Charlie, LLC and Lyons National Bank counsel and
Defendants Trinidad Entities for purposes of NYCRR 202.7 (f) in this matter as follows:
Jayla R. Lombardo, Esq. Marc W. Brown, Esq.
LOMBARDO LAW, PLLC GOLDBERG SEGALLA, LLP
Attorneys for Plaintiff Attorneys for Defendants Lima Charlie, LLC
69 Cascade Drive and Lyons National Bank
Suite 102 665 Main Street
Rochester, New York 14614 Buffalo, New York 14203
E: jlombardo@lombardoattorney.com E: mwbrown@goldbergsegalla.com
Maria Trinidad
101 Salem Rd
Valley Stream, New York 11580
E: jenlen57@gmail.com
A copy of the notification letter is submitted herewith.
Dated: Brooklyn, New York
October 14, 2022
________________________
Charles W. Marino, Esq.
SHAROVA LAW FIRM
147 Prince St, 4th Floor
Brooklyn, New York 11201
(718) 766-5153
3 of 7
FILED: MONROE COUNTY CLERK 10/14/2022 11:29 AM INDEX NO. E2020008624
NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 10/14/2022
Charles Marino
Index No: E2020008624 // Ramdas Shanbag, et. al. v Maria Trinidad, et. al.
1 message
Charles Marino Thu, Oct 13, 2022 at 6:11 PM
To: Jayla Lombardo , "Brown, Marc W." ,
jmacri@goldbergsegalla.com
Counsel,
Please see attached notice pursuant to NYCRR 202.7(f).
--
--
Very truly yours,
Charles W. Marino, Esq.
147 Prince Street, 4th Floor
Brooklyn, New York 11201
T. 718-766-8858
F. 718-504-3599
msantana@sharovalaw.com
www.sharovalaw.com
This message contains confidential information and is intended only for the individual
named above as the recipient. If you are not the named recipient you should not
disseminate, distribute or copy this e-mail.Further, no information contained in this
email is to be considered binding and cannot be used for litigation purpose,unless the
text of the email indicates otherwise. Please notify the sender immediately by e-mail
if you have received this e-mail by mistake and delete this e-mail from your system
immediately.
E-mail transmission cannot be guaranteed to be secure or error-free as information
could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain
viruses. The sender therefore does not accept liability for any errors or omissions in
the contents of this message which arise as a result of e-mail transmission. If
verification is required please request a hard-copy version. This message is provided
for informational purposes and should not be construed as legal advice or opinion.
Notice pursuant to 202.7 - Counsel.pdf
104K
4 of 7
FILED: MONROE COUNTY CLERK 10/14/2022 11:29 AM INDEX NO. E2020008624
NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 10/14/2022
Telephone 1.718.766.5153
Facsimile 1.718.504.3599
Email cmarino@sharovalaw.com
PARALEGALS:
YELENA SHAROVA, ESQ. *+ FRANKLIN DAVIS JR
SASSY DUMORNAY ESQ. * ALVIN KORSUNSKIY
CHARLES KASER ESQ. * CELINA QUEVEDO
NANI KIM ESQ. * MABEL SANTANA
CHARLES MARINO ESQ. * GRIGORIY SHUBA
BRUCE PROVDA ESQ. * HANNA SKARULIS
THOMAS J. TYRRELL JR. ESQ. *
*NY +NJ
October 13, 2022
VIA ELECTRONIC MAIL
Jayla R. Lombardo, Esq. Marc W. Brown, Esq.
LOMBARDO LAW, PLLC GOLDBERG SEGALLA, LLP
Attorneys for Plaintiff Attorneys for Defendants Lima Charlie, LLC
69 Cascade Drive and Lyons National Bank
Suite 102 665 Main Street
Rochester, New York 14614 Buffalo, New York 14203
E: jlombardo@lombardoattorney.com E: mwbrown@goldbergsegalla.com
Re: Ramdas Shanbag, et. al. v Maria Trinidad, et. al.
Index No.: E2020008624
Counsel,
We will present an Order to Show Cause to the Supreme Court, Monroe County, on Friday
October 14th, 2022 at 11:00am. The Order to Show Cause will be presented by electronic
submission via NYSCEF.
The relief sought is an application seeking to be relieved as counsel for Defendants
JENLEN, LLC; JENLEN 401K PLAN FBO MARIA TRINIDAD; JENLEN, LLC, REVOCABLE
LIVING TRUST and EQUITY TRUST COMPANY, CUSTODIAN, FBO MARIA TRINIDAD
and a temporary restraining order pending the determination of the Order to Show Cause.
This notice is provided to you pursuant to NYCRR 202.7(f). Please be guided accordingly.
Very truly yours,
/s/ Charles W. Marino
147 PRINCE STREET,4TH FLOOR, BROOKLYN, NEW YORK 11201
5 of 7
FILED: MONROE COUNTY CLERK 10/14/2022 11:29 AM INDEX NO. E2020008624
NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 10/14/2022
Charles Marino
***RELATED TO A COURT PROCEEDING*** Index No: E2020008624 // Ramdas
Shanbag, et. al. v Maria Trinidad, et. al.
2 messages
Charles Marino Thu, Oct 13, 2022 at 6:09 PM
To: Maria Trinidad
Ms. Trinidad,
Please see attached notice pursuant to NYCRR 202.7(f). This matter is related to a court proceeding.
--
--
Very truly yours,
Charles W. Marino, Esq.
147 Prince Street, 4th Floor
Brooklyn, New York 11201
T. 718-766-8858
F. 718-504-3599
msantana@sharovalaw.com
www.sharovalaw.com
This message contains confidential information and is intended only for the individual
named above as the recipient. If you are not the named recipient you should not
disseminate, distribute or copy this e-mail.Further, no information contained in this
email is to be considered binding and cannot be used for litigation purpose,unless the
text of the email indicates otherwise. Please notify the sender immediately by e-mail
if you have received this e-mail by mistake and delete this e-mail from your system
immediately.
E-mail transmission cannot be guaranteed to be secure or error-free as information
could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain
viruses. The sender therefore does not accept liability for any errors or omissions in
the contents of this message which arise as a result of e-mail transmission. If
verification is required please request a hard-copy version. This message is provided
for informational purposes and should not be construed as legal advice or opinion.
Notice pursuant to 202.7 - Defendant.pdf
88K
Lena Martinez Fri, Oct 14, 2022 at 5:55 AM
To: Maria Trinidad , cmarino@sharovalaw.com, sharova@sharovalaw.com
Hello,
6 of 7
FILED: MONROE COUNTY CLERK 10/14/2022 11:29 AM INDEX NO. E2020008624
NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 10/14/2022
Telephone 1.718.766.5153
Facsimile 1.718.504.3599
Email cmarino@sharovalaw.com
PARALEGALS:
YELENA SHAROVA, ESQ. *+ FRANKLIN DAVIS JR
SASSY DUMORNAY ESQ. * ALVIN KORSUNSKIY
CHARLES KASER ESQ. * CELINA QUEVEDO
NANI KIM ESQ. * MABEL SANTANA
CHARLES MARINO ESQ. * GRIGORIY SHUBA
BRUCE PROVDA ESQ. * HANNA SKARULIS
THOMAS J. TYRRELL JR. ESQ. *
*NY +NJ
October 13, 2022
VIA ELECTRONIC MAIL
Maria Trinidad
101 Salem Rd
Valley Stream, New York 11580
Re: Ramdas Shanbag, et. al. v Maria Trinidad, et. al.
Index No.: E2020008624
Ms. Trinidad,
We will present an Order to Show Cause to the Supreme Court, Monroe County, on Friday
October 14th, 2022 at 11:00am. The Order to Show Cause will be presented by electronic
submission via NYSCEF.
The relief sought is an application seeking to be relieved as counsel of Defendants
JENLEN, LLC; JENLEN 401K PLAN FBO MARIA TRINIDAD; JENLEN, LLC, REVOCABLE
LIVING TRUST and EQUITY TRUST COMPANY, CUSTODIAN, FBO MARIA TRINIDAD
and a temporary restraining order pending the determination of the Order to Show Cause.
This notice is provided to you pursuant to NYCRR 202.7(f). Please be guided accordingly.
Very truly yours,
/s/ Charles W. Marino
147 PRINCE STREET,4TH FLOOR, BROOKLYN, NEW YORK 11201
7 of 7
Preview
FILED: MONROE COUNTY CLERK 10/14/2022 11:29 AM INDEX NO. E2020008624 NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 10/14/2022 MONROE COUNTY CLERK’S OFFICE THIS IS NOT A BILL. THIS IS YOUR RECEIPT. Receipt # Book Page Return To: No. Pages: 7 YELENA SHAROVA 147 PRINCE STREET, 4TH FLOOR Instrument: AFFIRMATION BROOKLYN, NY 11201 Control #: Unrecorded #9100302 Index #: E2020008624 Date: Shanbhag, Ramdas Time: Shanbhag, Ramdas Trinidad, Maria Jen Len, LLC Jen Len 401 K Plan FBO Maria Trinidad Jen Len, LLC, Revocable Living Trust Equity Trust Company, Custodian, FBO, Maria Trinidad Total Fees Paid: $0.00 Employee: State of New York MONROE COUNTY CLERK’S OFFICE WARNING – THIS SHEET CONSTITUTES THE CLERKS ENDORSEMENT, REQUIRED BY SECTION 317-a(5) & SECTION 319 OF THE REAL PROPERTY LAW OF THE STATE OF NEW YORK. DO NOT DETACH OR REMOVE. JAMIE ROMEO MONROE COUNTY CLERK 1 of 7 FILED: MONROE COUNTY CLERK 10/14/2022 11:29 AM INDEX NO. E2020008624 NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 10/14/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF MONROE ---------------------------------------------------------------------x RAMDAS SHANBHAG and Index No.: E2020008624 RAMDAS SHANBHAG as Trustee for the RAMDAS SHANBHAG TRUST, Plaintiff, -against- NYCRR § 202.7(f) NOTICE AFFIRMATION MARIA TRINIDAD; JENLEN, LLC; JENLEN 401K PLAN FBO MARIA TRINIDAD; JENLEN, LLC, REVOCABLE LIVING TRUST; EQUITY TRUST COMPANY, CUSTODIAN, FBO MARIA TRINIDAD; LIMA CHARLIE, LLC; METRO CITY BANK; LYONS NATIONAL BANK; RADNAGE PROPERTY, LLC, and “JOHN DOE” and “MARY DOE”, said names being fictitious, parties intended being possible tenants or occupants of premises, and corporations, other entities or persons who claim, or may claim, a lien against the premises, Defendants. --------------------------------------------------------------------X CHARLES W. MARINO, ESQ., an attorney duly admitted to practice law in the State of New York affirms the truth of the following under the penalties of perjury pursuant to CPLR § 2106: 1. I am a member of the Sharova Law Firm, attorneys for the Defendants JENLEN, LLC; JENLEN 401K PLAN FBO MARIA TRINIDAD; JENLEN, LLC, REVOCABLE LIVING TRUST and EQUITY TRUST COMPANY, CUSTODIAN, FBO MARIA TRINIDAD (collectively “Defendants Trinidad Entities”), and as such am fully familiar with the facts, proceedings and circumstances herein. 2 of 7 FILED: MONROE COUNTY CLERK 10/14/2022 11:29 AM INDEX NO. E2020008624 NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 10/14/2022 2. This matter is brought before the Court by way of Order to Show Cause as procedurally we are seeking a preliminary injunction pursuant to CPLR § 6301. 3. On October 13, 2022 my office served notification via electronic email to the below listed Plaintiff’s counsel, Defendants Lima Charlie, LLC and Lyons National Bank counsel and Defendants Trinidad Entities for purposes of NYCRR 202.7 (f) in this matter as follows: Jayla R. Lombardo, Esq. Marc W. Brown, Esq. LOMBARDO LAW, PLLC GOLDBERG SEGALLA, LLP Attorneys for Plaintiff Attorneys for Defendants Lima Charlie, LLC 69 Cascade Drive and Lyons National Bank Suite 102 665 Main Street Rochester, New York 14614 Buffalo, New York 14203 E: jlombardo@lombardoattorney.com E: mwbrown@goldbergsegalla.com Maria Trinidad 101 Salem Rd Valley Stream, New York 11580 E: jenlen57@gmail.com A copy of the notification letter is submitted herewith. Dated: Brooklyn, New York October 14, 2022 ________________________ Charles W. Marino, Esq. SHAROVA LAW FIRM 147 Prince St, 4th Floor Brooklyn, New York 11201 (718) 766-5153 3 of 7 FILED: MONROE COUNTY CLERK 10/14/2022 11:29 AM INDEX NO. E2020008624 NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 10/14/2022 Charles Marino Index No: E2020008624 // Ramdas Shanbag, et. al. v Maria Trinidad, et. al. 1 message Charles Marino Thu, Oct 13, 2022 at 6:11 PM To: Jayla Lombardo , "Brown, Marc W." , jmacri@goldbergsegalla.com Counsel, Please see attached notice pursuant to NYCRR 202.7(f). -- -- Very truly yours, Charles W. Marino, Esq. 147 Prince Street, 4th Floor Brooklyn, New York 11201 T. 718-766-8858 F. 718-504-3599 msantana@sharovalaw.com www.sharovalaw.com This message contains confidential information and is intended only for the individual named above as the recipient. If you are not the named recipient you should not disseminate, distribute or copy this e-mail.Further, no information contained in this email is to be considered binding and cannot be used for litigation purpose,unless the text of the email indicates otherwise. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system immediately. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this message which arise as a result of e-mail transmission. If verification is required please request a hard-copy version. This message is provided for informational purposes and should not be construed as legal advice or opinion. Notice pursuant to 202.7 - Counsel.pdf 104K 4 of 7 FILED: MONROE COUNTY CLERK 10/14/2022 11:29 AM INDEX NO. E2020008624 NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 10/14/2022 Telephone 1.718.766.5153 Facsimile 1.718.504.3599 Email cmarino@sharovalaw.com PARALEGALS: YELENA SHAROVA, ESQ. *+ FRANKLIN DAVIS JR SASSY DUMORNAY ESQ. * ALVIN KORSUNSKIY CHARLES KASER ESQ. * CELINA QUEVEDO NANI KIM ESQ. * MABEL SANTANA CHARLES MARINO ESQ. * GRIGORIY SHUBA BRUCE PROVDA ESQ. * HANNA SKARULIS THOMAS J. TYRRELL JR. ESQ. * *NY +NJ October 13, 2022 VIA ELECTRONIC MAIL Jayla R. Lombardo, Esq. Marc W. Brown, Esq. LOMBARDO LAW, PLLC GOLDBERG SEGALLA, LLP Attorneys for Plaintiff Attorneys for Defendants Lima Charlie, LLC 69 Cascade Drive and Lyons National Bank Suite 102 665 Main Street Rochester, New York 14614 Buffalo, New York 14203 E: jlombardo@lombardoattorney.com E: mwbrown@goldbergsegalla.com Re: Ramdas Shanbag, et. al. v Maria Trinidad, et. al. Index No.: E2020008624 Counsel, We will present an Order to Show Cause to the Supreme Court, Monroe County, on Friday October 14th, 2022 at 11:00am. The Order to Show Cause will be presented by electronic submission via NYSCEF. The relief sought is an application seeking to be relieved as counsel for Defendants JENLEN, LLC; JENLEN 401K PLAN FBO MARIA TRINIDAD; JENLEN, LLC, REVOCABLE LIVING TRUST and EQUITY TRUST COMPANY, CUSTODIAN, FBO MARIA TRINIDAD and a temporary restraining order pending the determination of the Order to Show Cause. This notice is provided to you pursuant to NYCRR 202.7(f). Please be guided accordingly. Very truly yours, /s/ Charles W. Marino 147 PRINCE STREET,4TH FLOOR, BROOKLYN, NEW YORK 11201 5 of 7 FILED: MONROE COUNTY CLERK 10/14/2022 11:29 AM INDEX NO. E2020008624 NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 10/14/2022 Charles Marino ***RELATED TO A COURT PROCEEDING*** Index No: E2020008624 // Ramdas Shanbag, et. al. v Maria Trinidad, et. al. 2 messages Charles Marino Thu, Oct 13, 2022 at 6:09 PM To: Maria Trinidad Ms. Trinidad, Please see attached notice pursuant to NYCRR 202.7(f). This matter is related to a court proceeding. -- -- Very truly yours, Charles W. Marino, Esq. 147 Prince Street, 4th Floor Brooklyn, New York 11201 T. 718-766-8858 F. 718-504-3599 msantana@sharovalaw.com www.sharovalaw.com This message contains confidential information and is intended only for the individual named above as the recipient. If you are not the named recipient you should not disseminate, distribute or copy this e-mail.Further, no information contained in this email is to be considered binding and cannot be used for litigation purpose,unless the text of the email indicates otherwise. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system immediately. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this message which arise as a result of e-mail transmission. If verification is required please request a hard-copy version. This message is provided for informational purposes and should not be construed as legal advice or opinion. Notice pursuant to 202.7 - Defendant.pdf 88K Lena Martinez Fri, Oct 14, 2022 at 5:55 AM To: Maria Trinidad , cmarino@sharovalaw.com, sharova@sharovalaw.com Hello, 6 of 7 FILED: MONROE COUNTY CLERK 10/14/2022 11:29 AM INDEX NO. E2020008624 NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 10/14/2022 Telephone 1.718.766.5153 Facsimile 1.718.504.3599 Email cmarino@sharovalaw.com PARALEGALS: YELENA SHAROVA, ESQ. *+ FRANKLIN DAVIS JR SASSY DUMORNAY ESQ. * ALVIN KORSUNSKIY CHARLES KASER ESQ. * CELINA QUEVEDO NANI KIM ESQ. * MABEL SANTANA CHARLES MARINO ESQ. * GRIGORIY SHUBA BRUCE PROVDA ESQ. * HANNA SKARULIS THOMAS J. TYRRELL JR. ESQ. * *NY +NJ October 13, 2022 VIA ELECTRONIC MAIL Maria Trinidad 101 Salem Rd Valley Stream, New York 11580 Re: Ramdas Shanbag, et. al. v Maria Trinidad, et. al. Index No.: E2020008624 Ms. Trinidad, We will present an Order to Show Cause to the Supreme Court, Monroe County, on Friday October 14th, 2022 at 11:00am. The Order to Show Cause will be presented by electronic submission via NYSCEF. The relief sought is an application seeking to be relieved as counsel of Defendants JENLEN, LLC; JENLEN 401K PLAN FBO MARIA TRINIDAD; JENLEN, LLC, REVOCABLE LIVING TRUST and EQUITY TRUST COMPANY, CUSTODIAN, FBO MARIA TRINIDAD and a temporary restraining order pending the determination of the Order to Show Cause. This notice is provided to you pursuant to NYCRR 202.7(f). Please be guided accordingly. Very truly yours, /s/ Charles W. Marino 147 PRINCE STREET,4TH FLOOR, BROOKLYN, NEW YORK 11201 7 of 7