Preview
FILED: NASSAU COUNTY CLERK 05/16/2023 12:14 PM INDEX NO. 607877/2023
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/16/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
Index No.:
VOX FUNDING LLC,
Plaintiff, Venue: NASSAU
-against-
A GALAXY OF STARS CHILD CARE CENTER, LLC
Basis of venue designated: Contract
AND LASHUNDA ANTEECE LANE GLASGOW,
Defendants. SUMMONS
TO THE ABOVE-NAMED DEFENDANTS:
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 the plaintiff’s attorney within 20 days after the service of this summons,
exclusive of the day of service (or within 30 days after the service is complete if this summons is
not personally delivered to you within the State of New York); and in case of your failure to
appear or answer, judgment will be taken against you by default for the relief demanded in the
complaint.
Dated: Nassau County, New York
May 16, 2023
LIEBERMAN AND KLESTZICK, LLP
Yonatan Klestzick, Esq.
71 S. Central Avenue, 2nd Floor
Valley Stream, New York 11580
Mail To:
PO Box 356
Cedarhurst, New York 11516
PHONE: (516) 900-6720
FAX: (516) 308-9383
YKlestzick@landklegal.com
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To Defendant’s Addresses:
A GALAXY OF STARS CHILD CARE CENTER, LLC
1626 TOWNE DRIVE, COLUMBIA, MO, 65202
4314 PEREGRINE PLACE, COLUMBIA, MO 65202
LASHUNDA ANTEECE LANE-GLASGOW
1626 TOWNE DRIVE, COLUMBIA, MO, 65202
4314 PEREGRINE PLACE, COLUMBIA, MO 65202
SEE COMPLAINT ANNEXED HERETO
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
VOX FUNDING LLC, Index No.:
Plaintiff,
-against-
A GALAXY OF STARS CHILD CARE CENTER, LLC
AND LASHUNDA ANTEECE LANE GLASGOW,
VERIFIED COMPLAINT
Defendants.
Plaintiff, VOX FUNDING LLC (“Plaintiff”), by and through its attorneys,
Lieberman and Klestzick, LLP, for its complaint herein against A GALAXY OF STARS
CHILD CARE CENTER, LLC (“Company Defendant”), and LASHUNDA ANTEECE
LANE-GLASGOW (“Guarantor”, and together with the Company Defendant the
“Defendants”), alleges as follows:
The Parties
1. At all relevant times Plaintiff was and is a Foreign Limited Liability Company
registered to do business and with an office in the State of New York.
2. Upon information and belief, at all relevant times, Company Defendant was
and is a company organized and existing under the laws of the State of Missouri that
agreed that any action between the parties be instituted in any court sitting in New York
State.
3. Upon information and belief, at all relevant times, Guarantor was and is an
individual residing in the state of Missouri who agreed that any action between the parties
be instituted in any court sitting in New York State.
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4. The subject contract between the parties states that any litigation related hereto
must be commenced and maintained in any court located in the State of New York. See
Agreement, page 7 paragraph 27, attached as Exhibit “A”.
The Facts
5. On or about December 09, 2022, Plaintiff and Defendants entered into an
agreement (The “Agreement”) whereby Plaintiff agreed to purchase 17 percent of
Company Defendant’s future receivables having an agreed to value of $56,800.00. See
the Agreement annexed hereto as “Exhibit A”.
6. Pursuant to the Agreement, Company Defendant agreed to have one bank
account approved by Plaintiff (the “Bank Account”) from which Company Defendant
authorized Plaintiff to make ACH withdrawals until $56,800.00 was paid in full to
Plaintiff.
7. In addition, Guarantor agreed to guarantee any and all amounts owed to
Plaintiff from Company Defendant upon a breach in performance by Company
Defendant.
8. Plaintiff remitted $40,000.00, minus the agreed to fees, and less the prior
balance pursuant to the “Purchase Detail” on page 1 of the Agreement, “the purchase
price” pursuant to the Agreement, for the future receivables to Company Defendant as
Agreed. See page 1 of the Agreement annexed hereto as Exhibit “A”.
9. Company Defendant, however, intentionally stopped remitting the purchased
receivables to Plaintiff from the Bank Account without proper notice and failed to
provide Plaintiffs proper financial disclosures or a written request for reconciliation,
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thereby breaching the agreement.
10. Company Defendant is in breach of the Agreement as of, on or about, January
26, 2023.
11. Company Defendant made payments totaling $11,360.76, leaving a balance
due of $45,439.24. See the Pay Run annexed hereto as “Exhibit B”.
12. Company Defendant owes Plaintiff $45,439.24 of the Purchased Amount.
13. By Defaulting, under the terms of the Agreement, Company Defendant owes
Plaintiff an additional $5,000.00 default fee. See Exhibit “A” at page 2 paragraph H(b).
14. Company Defendant owes Plaintiff $150.00 for Not Sufficient Funds (“NSF”)
fees under the Agreement due to instances in which Plaintiff’s withdrawals from the Bank
Account were rejected for insufficient funds. See Exhibit “A” page 2 paragraph D.
15. Despite due demand, Company Defendant has failed to pay the amounts due
and owing by Company Defendant to Plaintiff under the Agreement.
16. Additionally, Guarantor is responsible for all amounts incurred as a result of
any default of the Company Defendant.
17. There remains a balance due and owing to Plaintiff on the Agreement in the
amount of $50,439.24 plus interests, costs, disbursements and attorney’s fees.
AS AND FOR THE FIRST CAUSE OF ACTION
(Breach of Contract)
18. Plaintiff repeats and re-alleges each and every allegation contained in
paragraphs 1 through 17 of this complaint as though fully set forth at length herein.
19. Plaintiff gave fair consideration to Company Defendant which was tendered
for the right to receive the aforementioned future receivables. Accordingly, Plaintiff fully
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performed under the Agreement.
20. Upon information and belief, Company Defendant is still conducting regular
business operations and still collecting receivables.
21. Company Defendant has materially breached the Agreement by intentionally
stopping the remittance of the purchased receivables to Plaintiff from the Bank Account
without proper notice, without providing proper financial disclosures or a written request
for reconciliation, and otherwise intentionally impeding and preventing Plaintiff from
receiving the proceeds of the receivables purchased by them while conducting regular
business operations thereby breaching the Agreement.
22. By reason of the foregoing, Plaintiff has suffered damages in the amount of
$50,439.24, plus interest, costs, disbursements and attorney’s fees.
AS AND FOR A SECOND CAUSE OF ACTION
(Personal Guarantee)
23. Plaintiff repeats and re-alleges each and every allegation contained in paragraphs
1 through 22 of this complaint as though fully set forth at length herein.
24. Pursuant to the Agreement, Guarantor personally guaranteed that Company
Defendant would perform its obligations thereunder and that she would be personally liable
for any loss suffered by Plaintiff as a result of a breach by Company Defendant.
25. Company Defendant has breached the Agreement as detailed above.
26. By reason of the foregoing, Plaintiff is entitled to judgment against Guarantor
based on her personal guarantee in the sum of $50,439.24, plus interests, costs,
disbursements and attorney’s fees.
AS AND FOR A THIRD CAUSE OF ACTION
(Unjust Enrichment)
27. Plaintiff repeats and re-alleges each and every allegation contained in paragraphs
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1 through 26 of this complaint as though fully set forth at length herein.
28. Defendants have been unjustly enriched in that they have received the
purchase price for the future receivables yet have failed to pay the sum of $45,439.24
pursuant to the Agreement.
29. By reason of the foregoing, Plaintiff is entitled to judgment against the
Defendants for unjust enrichment in an amount to be determined by the court, plus
interest, costs, disbursements and attorney’s fees.
WHEREFORE, plaintiff VOX FUNDING LLC, requests judgment against
defendants A GALAXY OF STARS CHILD CARE CENTER, LLC AND
LASHUNDA ANTEECE LANE-GLASGOW as follows:
i. On the first cause of action of the complaints, Plaintiff requests judgment
against Company Defendant in the amount of $50,439.24 plus interest, costs,
disbursements and attorney’s fees;
ii. On the second cause of action of the complaint, Plaintiff requests judgment
against the Guarantor in the amount of $50,439.24, plus interest, costs,
disbursements and attorney’s fees;
iii. On the third cause of action of the complaint, Plaintiff requests judgment
against Company Defendant and Guarantor in the amount of $45,439.24, plus
interest, costs, disbursements and attorney’s fees;
iv. For such other and further relief as this Court deems just and proper.
Dated: Nassau County, New York
May 16, 2023
LIEBERMAN AND KLESTZICK, LLP
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Yonatan Klestzick, Esq.
71 S. Central Avenue, 2nd Floor
Valley Stream, New York 11580
Mail To:
PO Box 356, Cedarhurst, New York 11516
PHONE: (516) 900-6720
YKlestzick@landklegal.com
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
VOX FUNDING LLC, Index No.:
Plaintiff, NOTICE OF ELECTRONIC FILING IN A
-against- MANDATORY CASE (Rule § 202.5-bb)
A GALAXY OF STARS CHILD CARE
CENTER, LLC AND LASHUNDA ANTEECE
LANE GLASGOW,
Defendants.
You have received this Notice because: 1) The Plaintiff/Petitioner, whose name is listed above, has filed
this case using the New York State Courts E-filing system (“NYSCEF”), and 2) You are a
Defendant/Respondent (a party) in this case.
If you are represented by an attorney: Give this Notice to your attorney. Attorneys: See Information for
Attorneys below.
If you are not represented by an attorney: You will be served with all documents in paper and you
must serve and file your documents in paper, unless you choose to participate in e-filing. If you choose to
participate in e-filing, you must have access to a computer and a scanner or other device to convert
documents into electronic format, a connection to the internet, and an e-mail address to receive service of
documents. The benefits of participating in e-filing include: 1) serving and filing your documents
electronically; 2) free access to view and print your e-filed documents; 3) limiting your number of trips to
the courthouse; 4) paying any court fees on-line (credit card needed).
To register for e-filing or for more information about how e-filing works: 1) visit:
www.nycourts.gov/efile-unrepresented; or 2) contact the Clerk’s Office or Help Center at the court where
the case was filed. Court contact information can be found at www.nycourts.gov.
To find legal information to help you represent yourself visit www.nycourthelp.gov.
Information for Attorneys – (E-filing is Mandatory for Attorneys): An attorney representing a party
who is served with this notice must either: 1) immediately record his or her representation with the e-filed
matter on the NYSCEF site www.nycourts.gov/efile; or 2) file the Notice of Opt-Out form with the clerk
of the court where this action is pending and serve on all parties. Exemptions form mandatory e-filing are
limited to attorneys who certify in good faith that they lack the computer hardware and/or scanner and/or
internet connection or that they lack (along with all employees subject to their direction) the knowledge to
operate such equipment. [Section 202.5-bb(e)]. For additional information about electronic filing and to
create a NYSCEF account, visit the NYSCEF website at www.nycourts.gov/efile or contact the NYSCEF
Resource Center (phone: 646-386-3033; email: efile@nycourts.gov).
Dated: Nassau County, New York
May 16, 2023
Yonatan Klestzick, Esq.
71 S. Central Avenue, Second Floor
Valley Stream, New York 11580
Mail To:
PO Box 356, Cedarhurst, New York 11516
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Index No.
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
VOX FUNDING LLC,
Plaintiff,
-against-
A GALAXY OF STARS CHILD CARE CENTER, LLC AND LASHUNDA
ANTEECE LANE GLASGOW
Defendants.
SUMMONS AND VERIFIED COMPLAINT
LIEBERMAN AND KLESTZICK, LLP
71 S. Central Avenue, Second Floor
Valley Stream, New York 11580
Mail To:
PO Box 356
Cedarhurst, New York 11516
11 of 11
Preview
FILED: NASSAU COUNTY CLERK 05/16/2023 12:14 PM INDEX NO. 607877/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/16/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU Index No.: VOX FUNDING LLC, Plaintiff, Venue: NASSAU -against- A GALAXY OF STARS CHILD CARE CENTER, LLC Basis of venue designated: Contract AND LASHUNDA ANTEECE LANE GLASGOW, Defendants. SUMMONS TO THE ABOVE-NAMED DEFENDANTS: 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 the plaintiff’s attorney within 20 days after the service of this summons, exclusive of the day of service (or within 30 days after the service is complete if this summons is not personally delivered to you within the State of New York); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. Dated: Nassau County, New York May 16, 2023 LIEBERMAN AND KLESTZICK, LLP Yonatan Klestzick, Esq. 71 S. Central Avenue, 2nd Floor Valley Stream, New York 11580 Mail To: PO Box 356 Cedarhurst, New York 11516 PHONE: (516) 900-6720 FAX: (516) 308-9383 YKlestzick@landklegal.com 1 of 11 FILED: NASSAU COUNTY CLERK 05/16/2023 12:14 PM INDEX NO. 607877/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/16/2023 To Defendant’s Addresses: A GALAXY OF STARS CHILD CARE CENTER, LLC 1626 TOWNE DRIVE, COLUMBIA, MO, 65202 4314 PEREGRINE PLACE, COLUMBIA, MO 65202 LASHUNDA ANTEECE LANE-GLASGOW 1626 TOWNE DRIVE, COLUMBIA, MO, 65202 4314 PEREGRINE PLACE, COLUMBIA, MO 65202 SEE COMPLAINT ANNEXED HERETO 2 of 11 FILED: NASSAU COUNTY CLERK 05/16/2023 12:14 PM INDEX NO. 607877/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/16/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU VOX FUNDING LLC, Index No.: Plaintiff, -against- A GALAXY OF STARS CHILD CARE CENTER, LLC AND LASHUNDA ANTEECE LANE GLASGOW, VERIFIED COMPLAINT Defendants. Plaintiff, VOX FUNDING LLC (“Plaintiff”), by and through its attorneys, Lieberman and Klestzick, LLP, for its complaint herein against A GALAXY OF STARS CHILD CARE CENTER, LLC (“Company Defendant”), and LASHUNDA ANTEECE LANE-GLASGOW (“Guarantor”, and together with the Company Defendant the “Defendants”), alleges as follows: The Parties 1. At all relevant times Plaintiff was and is a Foreign Limited Liability Company registered to do business and with an office in the State of New York. 2. Upon information and belief, at all relevant times, Company Defendant was and is a company organized and existing under the laws of the State of Missouri that agreed that any action between the parties be instituted in any court sitting in New York State. 3. Upon information and belief, at all relevant times, Guarantor was and is an individual residing in the state of Missouri who agreed that any action between the parties be instituted in any court sitting in New York State. 3 of 11 FILED: NASSAU COUNTY CLERK 05/16/2023 12:14 PM INDEX NO. 607877/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/16/2023 4. The subject contract between the parties states that any litigation related hereto must be commenced and maintained in any court located in the State of New York. See Agreement, page 7 paragraph 27, attached as Exhibit “A”. The Facts 5. On or about December 09, 2022, Plaintiff and Defendants entered into an agreement (The “Agreement”) whereby Plaintiff agreed to purchase 17 percent of Company Defendant’s future receivables having an agreed to value of $56,800.00. See the Agreement annexed hereto as “Exhibit A”. 6. Pursuant to the Agreement, Company Defendant agreed to have one bank account approved by Plaintiff (the “Bank Account”) from which Company Defendant authorized Plaintiff to make ACH withdrawals until $56,800.00 was paid in full to Plaintiff. 7. In addition, Guarantor agreed to guarantee any and all amounts owed to Plaintiff from Company Defendant upon a breach in performance by Company Defendant. 8. Plaintiff remitted $40,000.00, minus the agreed to fees, and less the prior balance pursuant to the “Purchase Detail” on page 1 of the Agreement, “the purchase price” pursuant to the Agreement, for the future receivables to Company Defendant as Agreed. See page 1 of the Agreement annexed hereto as Exhibit “A”. 9. Company Defendant, however, intentionally stopped remitting the purchased receivables to Plaintiff from the Bank Account without proper notice and failed to provide Plaintiffs proper financial disclosures or a written request for reconciliation, 4 of 11 FILED: NASSAU COUNTY CLERK 05/16/2023 12:14 PM INDEX NO. 607877/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/16/2023 thereby breaching the agreement. 10. Company Defendant is in breach of the Agreement as of, on or about, January 26, 2023. 11. Company Defendant made payments totaling $11,360.76, leaving a balance due of $45,439.24. See the Pay Run annexed hereto as “Exhibit B”. 12. Company Defendant owes Plaintiff $45,439.24 of the Purchased Amount. 13. By Defaulting, under the terms of the Agreement, Company Defendant owes Plaintiff an additional $5,000.00 default fee. See Exhibit “A” at page 2 paragraph H(b). 14. Company Defendant owes Plaintiff $150.00 for Not Sufficient Funds (“NSF”) fees under the Agreement due to instances in which Plaintiff’s withdrawals from the Bank Account were rejected for insufficient funds. See Exhibit “A” page 2 paragraph D. 15. Despite due demand, Company Defendant has failed to pay the amounts due and owing by Company Defendant to Plaintiff under the Agreement. 16. Additionally, Guarantor is responsible for all amounts incurred as a result of any default of the Company Defendant. 17. There remains a balance due and owing to Plaintiff on the Agreement in the amount of $50,439.24 plus interests, costs, disbursements and attorney’s fees. AS AND FOR THE FIRST CAUSE OF ACTION (Breach of Contract) 18. Plaintiff repeats and re-alleges each and every allegation contained in paragraphs 1 through 17 of this complaint as though fully set forth at length herein. 19. Plaintiff gave fair consideration to Company Defendant which was tendered for the right to receive the aforementioned future receivables. Accordingly, Plaintiff fully 5 of 11 FILED: NASSAU COUNTY CLERK 05/16/2023 12:14 PM INDEX NO. 607877/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/16/2023 performed under the Agreement. 20. Upon information and belief, Company Defendant is still conducting regular business operations and still collecting receivables. 21. Company Defendant has materially breached the Agreement by intentionally stopping the remittance of the purchased receivables to Plaintiff from the Bank Account without proper notice, without providing proper financial disclosures or a written request for reconciliation, and otherwise intentionally impeding and preventing Plaintiff from receiving the proceeds of the receivables purchased by them while conducting regular business operations thereby breaching the Agreement. 22. By reason of the foregoing, Plaintiff has suffered damages in the amount of $50,439.24, plus interest, costs, disbursements and attorney’s fees. AS AND FOR A SECOND CAUSE OF ACTION (Personal Guarantee) 23. Plaintiff repeats and re-alleges each and every allegation contained in paragraphs 1 through 22 of this complaint as though fully set forth at length herein. 24. Pursuant to the Agreement, Guarantor personally guaranteed that Company Defendant would perform its obligations thereunder and that she would be personally liable for any loss suffered by Plaintiff as a result of a breach by Company Defendant. 25. Company Defendant has breached the Agreement as detailed above. 26. By reason of the foregoing, Plaintiff is entitled to judgment against Guarantor based on her personal guarantee in the sum of $50,439.24, plus interests, costs, disbursements and attorney’s fees. AS AND FOR A THIRD CAUSE OF ACTION (Unjust Enrichment) 27. Plaintiff repeats and re-alleges each and every allegation contained in paragraphs 6 of 11 FILED: NASSAU COUNTY CLERK 05/16/2023 12:14 PM INDEX NO. 607877/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/16/2023 1 through 26 of this complaint as though fully set forth at length herein. 28. Defendants have been unjustly enriched in that they have received the purchase price for the future receivables yet have failed to pay the sum of $45,439.24 pursuant to the Agreement. 29. By reason of the foregoing, Plaintiff is entitled to judgment against the Defendants for unjust enrichment in an amount to be determined by the court, plus interest, costs, disbursements and attorney’s fees. WHEREFORE, plaintiff VOX FUNDING LLC, requests judgment against defendants A GALAXY OF STARS CHILD CARE CENTER, LLC AND LASHUNDA ANTEECE LANE-GLASGOW as follows: i. On the first cause of action of the complaints, Plaintiff requests judgment against Company Defendant in the amount of $50,439.24 plus interest, costs, disbursements and attorney’s fees; ii. On the second cause of action of the complaint, Plaintiff requests judgment against the Guarantor in the amount of $50,439.24, plus interest, costs, disbursements and attorney’s fees; iii. On the third cause of action of the complaint, Plaintiff requests judgment against Company Defendant and Guarantor in the amount of $45,439.24, plus interest, costs, disbursements and attorney’s fees; iv. For such other and further relief as this Court deems just and proper. Dated: Nassau County, New York May 16, 2023 LIEBERMAN AND KLESTZICK, LLP 7 of 11 FILED: NASSAU COUNTY CLERK 05/16/2023 12:14 PM INDEX NO. 607877/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/16/2023 Yonatan Klestzick, Esq. 71 S. Central Avenue, 2nd Floor Valley Stream, New York 11580 Mail To: PO Box 356, Cedarhurst, New York 11516 PHONE: (516) 900-6720 YKlestzick@landklegal.com 8 of 11 FILED: NASSAU COUNTY CLERK 05/16/2023 12:14 PM INDEX NO. 607877/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/16/2023 9 of 11 FILED: NASSAU COUNTY CLERK 05/16/2023 12:14 PM INDEX NO. 607877/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/16/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU VOX FUNDING LLC, Index No.: Plaintiff, NOTICE OF ELECTRONIC FILING IN A -against- MANDATORY CASE (Rule § 202.5-bb) A GALAXY OF STARS CHILD CARE CENTER, LLC AND LASHUNDA ANTEECE LANE GLASGOW, Defendants. You have received this Notice because: 1) The Plaintiff/Petitioner, whose name is listed above, has filed this case using the New York State Courts E-filing system (“NYSCEF”), and 2) You are a Defendant/Respondent (a party) in this case. If you are represented by an attorney: Give this Notice to your attorney. Attorneys: See Information for Attorneys below. If you are not represented by an attorney: You will be served with all documents in paper and you must serve and file your documents in paper, unless you choose to participate in e-filing. If you choose to participate in e-filing, you must have access to a computer and a scanner or other device to convert documents into electronic format, a connection to the internet, and an e-mail address to receive service of documents. The benefits of participating in e-filing include: 1) serving and filing your documents electronically; 2) free access to view and print your e-filed documents; 3) limiting your number of trips to the courthouse; 4) paying any court fees on-line (credit card needed). To register for e-filing or for more information about how e-filing works: 1) visit: www.nycourts.gov/efile-unrepresented; or 2) contact the Clerk’s Office or Help Center at the court where the case was filed. Court contact information can be found at www.nycourts.gov. To find legal information to help you represent yourself visit www.nycourthelp.gov. Information for Attorneys – (E-filing is Mandatory for Attorneys): An attorney representing a party who is served with this notice must either: 1) immediately record his or her representation with the e-filed matter on the NYSCEF site www.nycourts.gov/efile; or 2) file the Notice of Opt-Out form with the clerk of the court where this action is pending and serve on all parties. Exemptions form mandatory e-filing are limited to attorneys who certify in good faith that they lack the computer hardware and/or scanner and/or internet connection or that they lack (along with all employees subject to their direction) the knowledge to operate such equipment. [Section 202.5-bb(e)]. For additional information about electronic filing and to create a NYSCEF account, visit the NYSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource Center (phone: 646-386-3033; email: efile@nycourts.gov). Dated: Nassau County, New York May 16, 2023 Yonatan Klestzick, Esq. 71 S. Central Avenue, Second Floor Valley Stream, New York 11580 Mail To: PO Box 356, Cedarhurst, New York 11516 10 of 11 FILED: NASSAU COUNTY CLERK 05/16/2023 12:14 PM INDEX NO. 607877/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/16/2023 Index No. SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU VOX FUNDING LLC, Plaintiff, -against- A GALAXY OF STARS CHILD CARE CENTER, LLC AND LASHUNDA ANTEECE LANE GLASGOW Defendants. SUMMONS AND VERIFIED COMPLAINT LIEBERMAN AND KLESTZICK, LLP 71 S. Central Avenue, Second Floor Valley Stream, New York 11580 Mail To: PO Box 356 Cedarhurst, New York 11516 11 of 11