Preview
FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023
[FILED: NEW YORK COUNTY CLERK 03 23 2023 09:51 AM INDEX
NO. 152683/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 06/13/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/23/2023
s
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
---------------------------------_-_----------------------------------x
JONATHAN THORSON AND GRACE SONG INDEX NO. ~ X2683/2023
Judgment Creditors
agauist - AFFIDAVIT IN SUPPORT QF
DOMESTICATII~IG A FOREIGN
EDDW, LLC, BDDW ]DESIGN, LLC, BDDW JUDGMEN'Y'
STUDIO, LLC, M. CROW LLC, TYLER HAYS a!k/a
TED TYLER HAYS
Judgment Debtors
x
STATE OF NEW YORK }
ss:
COUNTY OF NEW YORK
Kerry Gotlxb, being duly sworn deposes and says:
1. I am counsel to 3udgment Creditors, Jonathan Thorson ("Thorson") and Grace
Song ("Song"), and as such I am fully familiar wifh all facts and circtunstances as are set Earth
below.
2. I tnak~ this affidavit ira support of domesticating a judgment dated July b 2022, in
the Court Of Common Pleas, Philadelphia County, Stale of Pennsylvania, Index No. 01451
encaptioned "Jonathan Thorson and Grace Sang, Plain#iffs vs. EDDW, LLC, BDDW Design,
LLC, BDDW Studio, LLC, M. Crow LLC, Tyler Hays a/k!a TED TYLER HAYS, Garrett
McGlothlin, Eric Anderson and Jack Shelton" finding for Plaintiffs, Jonathan Thorson and Grace
Song, against Defendants, EDDW, LLC, BDDW DESIGN, LLC, BDDW Studio, LLC, M. Crow
LLC, Tyler Hays, in the swn of $2,160,782.75; allocated for Plaintiff, Jonathan Thorson in the
X amount of $£~fi4,313_l 0 and for Plaintiff, Grace Song in the amount of $~,29~,469.65. X
3. The referenced case, no. 01451 in the Court Of Common Pleas was commenced
in 2019, was fu11y defended and went to trial before Judge Vincent L. Johnson. The findings in
1
1 of 52
FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023
[FILF~D: NEW YORK COUNTY CLERK 03 23 2023 09:51 AM INDEX NO. 152683/20
23
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 06/13/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/23/2023
Plaisitiffs' favor wexe entered on July 6, 2022; a motion by Judgment Debtors for post-trial relief
was denied by the court on October 31, 2022 and Judgment Debtors' Motion to Vacate the
aforementioned Judgment after trial was denied on December 5, 2022. Defendants freely
participated in the adjudication of the matter.
4. The judgment was nit entered based on a default or by confession.
5. The amount of the judgment is outstanding; none of the sum awarded has been
laid.
6. The enforcement of the judgment has not been stayed. The Judgnnent Creditors
addresses aze:
Jonathan Thorson, 28-30 Greene Street, Unit SE, New York New York 10013
Grace Song, 818 North 4th Street, Unit 3B, Philadelphia PA 19123
The Judgment Debtors and their addresses are:
• EDDW, LLC, 3801 Jasper Street, Philadelphia PA 19124
• BDDW DESIGN, LLC, 3801 Jasper Street, Philadelphia PA 19124
• BDDW Studio, LLC, 3801 Jaspex Street, Philadelphia PA 19124
• M. Crow LLC, 3801 Jasper Street, Philadelphia PA 19124
• Tyler Hays alk/a Ted Tyler Hays, 3801 Jasper Street Philadelphia PA 19124
7. Interest on the judgment runs at 6% per annum, not compounded.
Wherefore upon the foregoing your deponent respectfully requests that the within foreign
judgment be domesticated and that judgerr~ent be entered against the Listed judgment debtors in
the sum of $2,160,782.75, with interest from July 6, 2022.
FILED
Sworn to before me on this _,,,K~J'UOGMEN
FOREIGN "'"" y ';~ TFeFROM Mar 23 2023
2 Z . day of March, 2023 STATE OF NEW YORK
PENNSYLVANIA COUNTY CLERK'S OFFICE
~ ~~ _
~.~'~
FELED PURSUANTTO-CPL-R-5402.
Z I~^ink SHry
unr~ ..., _ _i rAGo-c+'rTrZ
RegistratJonNo. 07 SA643~p ORiC
r^ Qualified in Kings
County
2 of 52
FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023
[FILED: NEW YORK COUNTY CLERK 03 23 2023 09:51 AM INDEX NO. 152683/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 06/13/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/23/2023
CAUTY4N: THIS DOCUMENT HAS NOT YET 88EN REVIEFIED BY THE COU2iTY CLERK. (See below.) INDEX NO. UNASSIGNED
NYSCEF DOC. NO. 1 RECEIVED iVXSCEF: 02/21/2023
,•• o~a~ubra' z.
LAMB McERLANE PC
13y: George C. Zumbano riled ;aad A~ s.t8~t~~by the
Jakc D. Becker Office ~~of, l~,a, i~ ~ :;records
Attome} I.D. ~los. 212~Sf3I5816 .411vrneysfor PlainJi[~5, ~ ~ ~`~~-y;.~~~ ~ ~ .
24 G. Markct Street
1'.O. Box 565
Wcst Chester. PA 19381-0565
JOI~ATE-IAN THORSON and IN THE COURT OF COM14]ON PLEAS
GRACE SONG, PHILADEZPHI.4 COUNTY, PA
Plaintiffs,
No. 0I451 MARCH TERM, 2019
EDDW, LLC, $I7DW DESIGN, LLC
BDDW STUD1O, LLC, vi. CROW L[,C,
TYLER HAYS, GARRETi'
McGLOTHLIN, ERIC ANDERSpN and
JACK SHELTOI~l,
Defendants.
PRAECIPE TO ENTE~t FINAL ,NDGMENT
TO THE OrFICE OF JUD1C[AL RECORDS:
Kindly enter judgment in favor of Plaintiffs, Jonathan Thorson and Grace Sung, pt~rsaant
to the Order entered .lUty 6, 2022, attached hereto as Exhibit "A", folIowing the denial of
Defendants' Motions for Post-Trial Relief, by Order entered October 31, 2022, attached hereto as
Exhibit "B". Specifically:
I. Enter judgment in favor ofPlaintif~, Jonathan Thorson, and against EDDW, LLC; BdDW
DESIGN, LLC; BDDW STUDIO, LLC; M. CROW, LLC; and TYLER HAYS a/k/a TED
TYLER HAYS, Defendants, in the amount of $8{14,3 i 3. i 0, plus interest from J aty 6, 2022,
pEus cflsts, and;
2. Enter judgment in favt~r of Plaintiff, Grace Song, and against EDDW, LLC; BDDW
DESIGN. LLC; BDDI~' STUDIO, i.LC; M. CROW, LLC; and TYLER HAYS a/ic/a TED
'TYLER ~-[AYS, Defendants. in the arnoant of $1,29b,469.65, plus interest from 3uly 6,
222, pius costs.
ThS.s is a copy o£ a pleading filed electronically pursuant to New York State coart rules (22
Case ID: J.90301451
NYCRR §202.5-b;d)(3){i))
xhich, at the tis~ o£ its printout from the court system's electronic xebsite, had not yeC been
xevieWed and
approved by the County Clerk. Because court rules (22 NYCRR'§2fl2.5[d]) author;zQ the County Clezk
to
Filings for various reasons, readers should be aware that documents bearing this legend may not have rajaet
been
accepted foz filing by the County Clerk. 3 pf 51
3 of 52
FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023
LFTLED: NEW YORK COUNTY CLERK 03 23 2023 09 • Sl AM INDEX NO. 152683/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 06/13/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/23/2023
CAUTION: T~tIS DOCUMENT yAS NOT YET BEEN REVIEWED gy THE COUNTY CLERIC. jSoo be].oK. ) INDEX NO. UNASSIGNED
NYSCEF DOC. NO. 1 RECEIVEQ NYSCEF: Q2/21/2023
In addition, please index the judgment in the ,fuclgment Index pursuant to Rule 302 t.
LAND McERLANE PC
Dated:lanuary 17, 2022 By. ~ev C. Zu~ftlitu~to-
George C, Zumbaao
Jake A. Bec,~cer
~Qttorneysfor Plaintiffs
Case ID:i9Q3a1451
This is a copy of a pleading Eiled electronically pursuant to Nev York State court rules (22 NYCRR §202.5-b(d}(3)ji))
which, at the time of its pra.ntout from the court ayatem's eiectroniC wWszte, had not yet bo.n
raviawad and
approved by the County Clack. Because coazt rules (22 NYCRR §202.5[dj) suthorisa tha County Clerk to reject
filings !or vaxious reasons, readers should be aware that documents bearing thin legend may not have been
accepted for filing by the County Clerk. 4 of SJ.
4 of 52
FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023
[FILE,D: NEW YORK COUNTY CLERK 03 23 2023 09:51 AM INDEX NO. 152683/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 06/13/2023
NXSCEF DOC. NO. 2 RECEIVED NYSCBF: 03/23/2023
CAUTION; THIS pOC1TMENT HAS NOT YET BEEN REVIEWED SX T&E COUNTY CLERK. ~8ee below.)
TNDEX N0. UNASSIGNED
NYSCEF DOC. H0. 1 RECEIVED NYSCEF: 02/21/2023
LAMB McERLAI~tE PC
By: Gcorge C. Zumbano
lake D. Becker
Attorney I.D. Nos. 21295/3! 5818 Alrorneys jor Plcrn~~(fs
24 E. Markct Street
P.O. Box 565
West Chester, PA 19381-0565
JONATHAN TF-iORS~N and IN THE COURT OF COMMON PLEAS
GRACE SONG, PHILADELPHIA COUTI'1'Y, PA
Piaintiff5,
No. 0145 I MARCH TERM, 2019
v.
EDDW, LLC, BDDW DESIGN, LLC
BDDW STUDIO, LLC, M. CROW LLC,
TYLER HAYS, GARRETT
McGLOTHLIN, ERIC ANDERSON and
JACK S[dELTON,
Defcndants.
CERTIFICATE OF SERVICE
This is to certsfy that in this case, complete copies of al l papers contained in the foregoing PrQecipe
to Enter F;na! Judgment was served upon the following by the following means and on the date stated
bolow:
Name: Means of Service: Date of Service'
Jeffrey J. Clarlaato, Esquit~e via emgi~ -JefJ~bdd~r.to~ 7anuary t7, 2023
Katclyn A. Feldstein, Esquire and kfeTdrteinQbddiv.com
3801 Jasper Street and First Class Ma!!
PhiEadelphia, PA 19124
David M. PromislaiF, Esquire t~ia email -je,~t bddiv,COdi
Promislof~'Law PC aid First Class Mail
5 Great Valley Parkway, St. 210
Malvern, YA 79355
LAMB McERLANE PC
By: Gear,-- C. Zu.,n~ia~to-
George C. Zumbano
Jake D. Becker
Attorneysfor Plaint
This is a copy of a pleading Filed electronically parsuant Lo Nea York State court zu].es (22 NYCAR
Case ID:1903U1.451
§202.5-b(d)(3j(i))
which, at the time of zts printout from the court system's electzonic website, had nat yat been reviewed
and
approvQd by the County Clerk. Because court xules (22 NYCRA §202.5[d]y authorize the Cavnty Clerk to reject
filings for various xeasons, readers should be aware that documents bearing thin legend may nod have been
accepted far filing by the County Clerk. 5 0~ 51
5 of 52
FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023
FILE: NEW YORK COUNTY CLERK 03 23 2023 Q9:51 AM INDEX NO. 152683/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 06/13/2023
NYSCEF DEC. NO. 2 RECEIVED NYSCEF: 03/23/2023
CAUTION: THIS DOCIII~NT HAS NOT YET BEEN REYZ$WEp SY TAE COONTY CLERIC, (See balax.) INDEX NO. UNASSIGNED
NYSCEF DOC. N0. 1 RECEIVED NYSCEF: 0 2 /2 1/2023
~XH~BIT "A"
Case ID: 190301.451
This ie a copy of a pleading filed electronically pursaant to Nex York State court rules (22 NYCRR
§202.5-b(d)(3}(1J)
xhSch, at the time of its printout from the Court syatmt's electzonic xebsita, had not yeL been
reviewed and
approved by tAo County Clerk. Seeause coart rules (22 NYCRR $202.5[dJ) authori.za Cho County Clark to
reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
acceQted for filing by the County Clerk, 6 of SZ
b of 52
FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023
[FILED: NEW YORK COUNTY CLERK 03 23 2023 09:51 AM INDEX IVO. 152683/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 06/13/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/23/2023
CAUTION: THZS DOCUN~NT HA$ NOT YET BEEN REVIEWED 8X T&E COIINTY CLERK. (See below.) INDEX NO. UNASSIGNED
NYSCEF DOC. NO. 1 RECEIVED NYSCEF; 02/ZI/2023
JONATHAN THdRSON and GRACE SON G COURT OF ~OMMQN PLEAS
Pf{iLADELPHlA COUNTY
Alaintiffs
MARCH TERM, 2U19
v. NO.01451
EDDW, LLC. BDDW DESIGN, !.l,,~
BDDW STUOTO, [,LG M. CROW Ll.C,
TYLER HAYS, GARRETT
McG1.QTHLITI, ERtC ANDERSON and
]ACK SHELTON.
Defendanl(s)
ORDER
,¢"
AND NOW this ~l} day of 3uly 2022, in consideration o€the foregoing Finding of Fact
and Conclusions of I.aw, the Court fends in favor of PIaindffs, Jonathan Thorson and Grace
Song, and against Dcfendanis, EDDW, LLC, BDDW Design, LLC, BDDW Studio. LLC, M.
Crow LLC, and Tyler Hays.
The Court finds that Fiaintiff, Jonathan Thorson, is entitled to 2% of the Defendants'
valuation of the business pies, as;iquidated damages, an amount egos[ to twenty-eve percent
(25%) of the total amount of wages due, which gives a total amount of X864,313.1Q.
The Court finds that Plaintiff. Cfrace Song, is entitled to 3% of Defendants' valuation of
the business plus, as liquidated dacnagts, an amount equal to twenty-five percent (2S%) of the
fatal amount of wages due of $1,296,469.65.
This is a copy of a pleading filed electronically pursuant to Neu York Slate court rules (22 NYCRR
Case ID:19O3Q1451
§202.5-bid)(3)~i)y
which, at the time of its printout from the court system's electronic vahsi.ta, had not yet been reviewed
and
appzoved by the County C1ezk. Because court rules (22 NYCAR §202.5(dJ) authozize the County Clerk to
reject
filings for various reasons, readers should be axare that documents bearing this legend may not have been
accepted for filing by the Caanty Clerk. '7 Of S1
7 of 52
FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023
FILED: NEW YORK COUNTY CLERK 03 23 2023 Q9:51 AM INDEX NO. 152&83/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 06/13/2023
NYSCEF DOC. NO. 2 RECEIVEp NYSCEF: 03/23/2023
CAUTION: THIS DQCI)MENT HAS NOT YET BEEN REVIEWED 8Y THE CAUNTY CLERK. (3ee below.) INI3EX NO. UNASSIGNED
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/21/2023
The Court finds that Plaintiff s counsel is entitled to attorney's cost and foes.'
ludgmwat is entered is favor of Plaintiffs, Jonathan Thanaa and Grace Song. and against
Defendants, EDDW, LLC, BDDW Design, LLC, BI~AW Studio. LI~C, M. Crow LLC, $nd Tyler
Hays.
BY THE COURT:
.~ J.
1 Plaintiff's t0un5ef Is to su6mlt a post-rerd9ct petition explalning theireosts and Fees incurred to relation to the
present matter.
This xa a copy of a pleading £i.7.ed electronically pursuant to N¢x York State court rules (22 NYCRR $202.5-b(d)(3y(iy}
Case ID:190301451
which, at the time of its printouC from Che court system's electronic websiLe, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR $202.S~dj) authorize the County Clerk to reject
filings for vazious reasons, reade=a should be aware that documents bearing this legend may not have been
accepted for filing by the County Clezk. g pf 51
8 of 52
FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023
FILED: NEW YORK COUNTY CLERK 03 23 2023 09:51
NYSCEF DOC. NO. 2 AM INDEX NO. 152683/2023
RECEIVED NYSCEF: 06/13/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/23/2023
CAUTION: THIS DOCVl~NT gAS NOT YET SEEN RBVIE9iED BY T~ COUNTY CLERIC. {SEC below.) INDEX NQ. UNASSIGNED
NXSGEF D0C. NO. 1 RECEIVED NXSCEF: 02/21/2023
EXH ~SIT "~"
Case ID:190301451
This ie a copy of a pleading filed electronically pursuant to Kew York State court rules (22 NYCRA 5202.5-b(d)(3?(i))
which, at the time o~ its printout Erom the court eystwn's electronic Mebane, had nat yet been reviexed and
approved by the County Clerk. Because court rules (22 NYCRR §20T.5[d]) authorize the County Clerk to reject
filings #or various reasons, readers should bo axase that dooumenta bearing thio legend may not bane bean
accepted Eor filing by the County Clerk. g of 52
9 of 52
FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023
[FILED: NEW YORK COtTNTY CLERK 03 23 2023 09:51 AM I~mEx NO. 152683/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 06/13/2023
NYSCEF DOC. IVO. 2 RECEIVED NYSCEF: 03/23/2x23
CAiITION: THIS DOCfTMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLER3C. (See below.) INDEX NO. UNASSIGNED
I~itSCEF DOC. NO. 1 ___. 3
JONATHAN THORSflNand GRACE SONG COURT OF COMMON PLEAS
PHILADELPHIA COUNTY
Plaintiffs
MARCH TERM, 2Q19
v. . NO.0I45 i
EDDW, LLC, BDDW DESIGN, LLC
BDDW SNDIO, LLC, M. CROW LLC,
TYLER HAYS, GARRETT
McGLOTHLIN, fiRIC ANDERSON and
.TACK SHEL"PON, ,
Qefendant(s)
ORDER
AND NOW, on taus 31~ day of October 2422, upon consideration of Defendants',
EDDW, LLC., BDDW Design, LLC., $DDW StucEio, LLC., M. Crow, LLC., and ~Fyler Hays,
Motion for Post-Trial Relief gurs~aai to PA.R.C.P.227.I, aad any response thcreto~ zt is hereby
ORDERED and DECREED that nefiendants' Motion is DENIED.
$Y r~ covRx:
T is is a copy of a Qleadiag £fled electronicaily pursuant to Neer York State court rules (22 NYCRR
Case ID: 190301451
v ich, at the time of ita printout from th¢ court 9y9tG16'9 e].ectroaic website, had not yet y202.5-b(d){3)(i))
been reviewed and
a proved by the County Clerk. Because court rules (22 NYCRR 5202.SjdJ)._authorxze the County
Clerk to zeject
filinga £or various zeasons, zeader~ should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. ]D Of 51
io of sa
FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023
FILED: NEW
NYSCEF DOC. NO. 2YORK COUNTY CLERK 03 23 2023 09:51 AM
INDEX NO. 152683/2023
RECEIVED NYSCEF: 06/13/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/23/2023
CAUTION: TFIIS DOCUt~NT HAS NOT YET HEEN REVIEWED SY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/21/2023
JO1~EATHAN THORSON and ItJ THE CURT OF CQMMON PLEAS
GRACE SONG, PHILADELPHIA COUNTY
No. i9-Q3-0fl1451
Plaintiffs,
MARCH TERM, 2Q19
v.
EDDW, LLC, SDDW DESIGN, LLC JURY TRlA~ DEMAl~iD6D
BDDW STUDIO, LLC, M. CROW LLC,
TYLER HAYS,GARRETT
McGi,OTHLIN, ERIC ANDERSON and
JACK SH~LTON,
Defendants.
JITDGMENT
,,~
On this day of ,ianuary, 2423, JUDGMENT is entered:
1. in favor of Jonathan Thorson and against EDDW, LLC; BDDW DESIGN, LL,C;
BDDW STUDIO, L[.C; M. CROW, LLC; and TYLER HAYS a/k/a TED TYLER
HAYS, an the amount of $Sb4,313.10, plus interest from 3uly 6, 2022, plus costs;
and
2. 1n favor ofGrace Song and against EDDW, LLC; BDDW DESIGN, LLC; SDDW
STUDIO, LLC; M. CROW, LLC; and TYLER HAYS aJkla TED TYLER HAYS,
in the amount $1,24b,469.65, plus interest ~6~om )uly 6, 24 2, plus costs.
OFFICE OF .RJDICIAL RECORDS
By:
Case ID:1~0341451
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §2D2.5-b(d)(3)(i))
which, at tha time of its printout from the court syecem's electronic website, had not yeC been reviewed and
appzoved by the County Clerk. 9eaause eaurt rules (22 NYCRR §202.5[dj) authorize the County Clerk to reject
filings for various reasons, readers should be aware that doeumeets bearing thza legenfl may not have been
accepted for filing by the County C.Ierk. ~~ Of S1
11 of 52
FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023
FILED: NO. 2YORK COUNTY CLERK 03 23 2023 09:51
NYSCEF DOC. NEW
INDEX
NO.
RECEIVED NYSCEF:
152683/20
23
06/13/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/23/2023
CAUTION: THIS DOC[JMERT HAS NOT X£T SEEN REVIEWED HY THE COUNTY CLLAK. (See below.)
=NDEX NO. UNASSIGNED
NXSCEF DOC. NO. 1 RECEIVED ATXSCEF: 02/21/2023
LAMB i41cERLAiVE PC
By: George C. Zumbano
Jake D. Beckcr
Attorney I.D. T2o5. 21295/315818 ~Itrorneysjnr Plalnr~
24 E. Market Street
P.O. Bos 565
West Chester, PA 19381-0565
JO~tATHAN THORSON and IN THE COURT OF COMMON PLEAS
GRACE SONG, FI~iILADELPHJA COUNTY, PA
PIaintiffs,
No. ~ 1451 MARCEt TERM, 2019
v.
EDDW, LLC, $bDW DESIGN, LLC
BDDW STUDIQ, LLC, M. CRAW LLC,
TYLER HAYS, GARRETT
McGLOT1-ILW, ERlC ANDERSON ar~d
JACK SHEi.TON,
Defendants.
NOTICE PURSUANT TO Pa.R.C.P 236
TO:
EDDW,LLC BDDW RESIGN, LLC $DDW STUDIO, LLC
3801 Jasper Street 3801 Jasper Street 3801 Jasper Street
Philadelphia, PA 39124 Phi lade~phia, PA 19124 Pfuladelph9a, PA 19 [2~
lYT. CROW LLC TXLER HAYS a/k/a
3801 Jasper Street TED TYLER HAYS
Pt~iladetphia~ PA 19124 3801 Jasper Street
Phi[adeiphia, PA 1924
YOU ARE HEREBY NOTIFIED THAT .TiJDGMENT HAS BEEN ENTERED AG.~irlST'
YOU AND IN FA'VUR U~ TAE F~LLLWING PARSONS IN THE FOL~OWWG AMOUNTS:
Judgment has been entered in favor of Plaintiff, Jonathan Thorson, and againstthe above-
named J~efendants in the amount of 5864,313.10, plus interest from July 6, 2022, plus costs.
Judgment has been entered in favor of Plaintiff, Grace Song, and against the above-named
Defendants in the amount of $1,296,469.65, plus interest from July b, 2022, plus costs.
DATE: OFFICE OF JUDICIAL RECORDS
This is a copy of a pleading EiJ.ed electronically pursuant to New York State courC
Case ID:190301451
Which, at the time of its printout Eram the Court system's electronic webaite, rules (22 NXCRR 5262.5-bid)(3){iy)
had not yet been reviewed and
approved by the County Clerk. Because courk zvles (22 NYCRR §202.5(d]) authorize the County
Filings for various =ea~ons, =coders should be aware that doceunents bearing this Clerk to reject
accepted for filing by the County Clerk. legend may not have been
12 OF S1
22 of 52
FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023
FILED: NEW
NYSCEF DOC. NO. 2YORK COUNTY CLERK 03 23 2023 09:51 AM
INDEX NO. 152683/20
23
RECEIVED NYSCEF: 06/13/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/23/2023
CAOTION: THIS DOCUMENT flAS NOT Y£T BEEN REVIEWED BY
THE CO[FT1TY CLERK. (See below.) INDEX NO. UNASSIGNED
NYSCEF DOC. N0. 1
RECEIVED NYSCEF: 02/21/2Q23
LAMB Mc~12LAiVE PC
By: Gcorge C. Zumbano
Iake D. Becker
Attorney I.D. Nos. 212951315818 Attorneysfor Plaint
24 E. Market Street
P.O. liox S65
West Chester, PA 193$1-0565
.f ONATHAN 'FHORSON and ITV TIC COURT OF COMMON PLEAS
GRAC£ SONG, PHILADELPHIA GOi1NTY, PA
Plaintiff's,
No. 0 f X51 MARCH TERM, 2019
v.
EDDW, LLCMBDDW DESIGN, LLC
BDDW STUDIQ, LLC, M. CROW LLC,
TYLER HAYS, GARRETT
McGLOTHLfItiT. ERiC ANpERSON and
JACK SHELTON,
Defendants.
CERTIFICATTON ~F ADbRESSES
I hereby certify that the following are the addresses of the fallowing Defendants:
EDDW, LLC BDDW DESIGN, LLC BDDW STUDIO, LLC
3801 Jasper Street, 38~I Jasper Street, 3801 Sasper Street
Philadelphia, PA 19124 Philadelphia, PA 19124 Philadelphia, PA 19 [24
M. CROW LLC TYLER HAYS alk/a
3501 Jasper Street, 'FED TYLER HAYS
Philadelphia, PA 19124 3801 ]riper Street
Philadelphia, PA 19125
LAMB McERLANE PC
Date: January 17, 2Q23 By: ~.or~,~iC. Zuan~tu2o-
George C. Zumbana
Jake D. Becker
Attorneys,for Plaintiff
This is a copy of a pleading filed electronically pursuant to New Yozk State
Case ID: 19O3O1451
which, nt the time of its printout From the court system's electronic webaite, court rules (22 NYCRA $202.5-bid?(3)(i))
had not yet been revfexed and
approved by the County Clerk. Because court rules (22 NXCRR
§2Q2.S(d1} autk~orize the County C2ezk to reject
#flings for various seasons, readers should be ar,+a=e that documents
bearing this legend may not have been
accepted for filing by the County Clezk. 'E3 Of 51
13 of 52
FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023
FILED: NEW
NYSCEF DOC. NO. 2YORK COUNTY CLERK 03 23 2023 09:51 AM INDEX NO. 152683/2023
RECEIVED NYSCEF: 06/13/2023
NYSCEF D0C. N'0. 2 RECEIVED NYSCEF: 03/23/2023
CAUTION: THIS DOCUMENT HAS NOT YET SEEN REVIEWED HY THE COUNTX CLERK. (See below.}
INDEX N0. UNASSIGNED
NYSCEF D0C. NO. 1 RECEIVED NYSCEF: 02/21/2023
Page 1
First judicial aistricE of ~'ezu~sylvania
~ 'Z'3aia1 Division-Civil
DC)CI~TREPORT
CASE I~i7MBER CASE CAP7TON .-. ..^
~ "` "'`""~ ~~8
TÌ€~ 19~301451 ZT~ORS(3NE'I'AL'VSEDDW,LLCE7'AL
FXT.kNG DATE: 12MAR2019 CURT: M1 JURY: N
CASE TYPE: CON'FTiACTS O'[~iER
STATUS: ~iJDGMENT ON COURTS FiNDiTiG
SLATED CASES:
Events;
• Bver+ED~iption Schedule .~-, Room! judge Name
'~ 5
DatQJXsme '` ~~- <~ocation ;y`
:.. ::~
MO'~ON HEA,~tING ~S-FEB-73 ~ COURTitOOM 2B5! JOHNSON, VIl1iCENT L
~9.3~Q0.~ ,,CPIYHALL ~ `~;;a.
Seq. No. Assoc Exprahon~ ~r,`~.~~azty; ~~. t~,.XD:~ ~ '~~PartvName/Address
1 GEORGE C
BT ST
PA I9381
~"°~6I0)692-0ff77-FAX
xizmbanoC~Iambma~rlane.aom
2 1 PLF _ ~1QS974t9 THOILSON, JONATHAN
28,30 GREEI~E ST
I.TI~TPI' 5E
NEW YORK, NY 10013
3 24 DFT ~105974Z0 SF~EL~ON, jAQC
1T25 MARLBOROUGH ST
PL~IILADELPHIA, PA 19725
4 1 PLF X10597421 SONG,GRACE
818N 4TH S~'
UIJIT 3B
PHILADELPHIA, PA I9323
5 ]3 DFI' ~1U597422 EDDW LLC
asozJ~~xsr .,-.~-
PHiLAD~LPHL~, PA ~;`~~,
6 13 X}kT X10547'473 BDDWDESIGNLLC ~~i~si,'` `~~
38QI~ASPQZST ~.;~~~~ ,
,. ~.. ~•.
PHILADELPHIA., PA 1
c~ oa/iir OB-F~-192] Q9 ~56:]O
A133=9739 c7[i'
Thzs is a copy of a pleading filed electronically pursuant to New York State court rules {22
which, at the time of ita p=iatout Erom the court system's electronic xebsite, had not yet NYCRA §202.5-b(d}(3}(i))
been reviewed and
approved by the County Clerk. Bocause count rules (22 NYCRA §202.5[d]) auhhoriza tho County Clerk'to
filings for various reasons, readers should be aaaare that documents bearing this .legend may not reject
accepted for filing by the CounCy Clerk. have been ~q Of 51
14 of 52
FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM
Preview
FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023 [FILED: NEW YORK COUNTY CLERK 03 23 2023 09:51 AM INDEX NO. 152683/2023 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 06/13/2023 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/23/2023 s SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ---------------------------------_-_----------------------------------x JONATHAN THORSON AND GRACE SONG INDEX NO. ~ X2683/2023 Judgment Creditors agauist - AFFIDAVIT IN SUPPORT QF DOMESTICATII~IG A FOREIGN EDDW, LLC, BDDW ]DESIGN, LLC, BDDW JUDGMEN'Y' STUDIO, LLC, M. CROW LLC, TYLER HAYS a!k/a TED TYLER HAYS Judgment Debtors x STATE OF NEW YORK } ss: COUNTY OF NEW YORK Kerry Gotlxb, being duly sworn deposes and says: 1. I am counsel to 3udgment Creditors, Jonathan Thorson ("Thorson") and Grace Song ("Song"), and as such I am fully familiar wifh all facts and circtunstances as are set Earth below. 2. I tnak~ this affidavit ira support of domesticating a judgment dated July b 2022, in the Court Of Common Pleas, Philadelphia County, Stale of Pennsylvania, Index No. 01451 encaptioned "Jonathan Thorson and Grace Sang, Plain#iffs vs. EDDW, LLC, BDDW Design, LLC, BDDW Studio, LLC, M. Crow LLC, Tyler Hays a/k!a TED TYLER HAYS, Garrett McGlothlin, Eric Anderson and Jack Shelton" finding for Plaintiffs, Jonathan Thorson and Grace Song, against Defendants, EDDW, LLC, BDDW DESIGN, LLC, BDDW Studio, LLC, M. Crow LLC, Tyler Hays, in the swn of $2,160,782.75; allocated for Plaintiff, Jonathan Thorson in the X amount of $£~fi4,313_l 0 and for Plaintiff, Grace Song in the amount of $~,29~,469.65. X 3. The referenced case, no. 01451 in the Court Of Common Pleas was commenced in 2019, was fu11y defended and went to trial before Judge Vincent L. Johnson. The findings in 1 1 of 52 FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023 [FILF~D: NEW YORK COUNTY CLERK 03 23 2023 09:51 AM INDEX NO. 152683/20 23 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 06/13/2023 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/23/2023 Plaisitiffs' favor wexe entered on July 6, 2022; a motion by Judgment Debtors for post-trial relief was denied by the court on October 31, 2022 and Judgment Debtors' Motion to Vacate the aforementioned Judgment after trial was denied on December 5, 2022. Defendants freely participated in the adjudication of the matter. 4. The judgment was nit entered based on a default or by confession. 5. The amount of the judgment is outstanding; none of the sum awarded has been laid. 6. The enforcement of the judgment has not been stayed. The Judgnnent Creditors addresses aze: Jonathan Thorson, 28-30 Greene Street, Unit SE, New York New York 10013 Grace Song, 818 North 4th Street, Unit 3B, Philadelphia PA 19123 The Judgment Debtors and their addresses are: • EDDW, LLC, 3801 Jasper Street, Philadelphia PA 19124 • BDDW DESIGN, LLC, 3801 Jasper Street, Philadelphia PA 19124 • BDDW Studio, LLC, 3801 Jaspex Street, Philadelphia PA 19124 • M. Crow LLC, 3801 Jasper Street, Philadelphia PA 19124 • Tyler Hays alk/a Ted Tyler Hays, 3801 Jasper Street Philadelphia PA 19124 7. Interest on the judgment runs at 6% per annum, not compounded. Wherefore upon the foregoing your deponent respectfully requests that the within foreign judgment be domesticated and that judgerr~ent be entered against the Listed judgment debtors in the sum of $2,160,782.75, with interest from July 6, 2022. FILED Sworn to before me on this _,,,K~J'UOGMEN FOREIGN "'"" y ';~ TFeFROM Mar 23 2023 2 Z . day of March, 2023 STATE OF NEW YORK PENNSYLVANIA COUNTY CLERK'S OFFICE ~ ~~ _ ~.~'~ FELED PURSUANTTO-CPL-R-5402. Z I~^ink SHry unr~ ..., _ _i rAGo-c+'rTrZ RegistratJonNo. 07 SA643~p ORiC r^ Qualified in Kings County 2 of 52 FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023 [FILED: NEW YORK COUNTY CLERK 03 23 2023 09:51 AM INDEX NO. 152683/2023 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 06/13/2023 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/23/2023 CAUTY4N: THIS DOCUMENT HAS NOT YET 88EN REVIEFIED BY THE COU2iTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 1 RECEIVED iVXSCEF: 02/21/2023 ,•• o~a~ubra' z. LAMB McERLANE PC 13y: George C. Zumbano riled ;aad A~ s.t8~t~~by the Jakc D. Becker Office ~~of, l~,a, i~ ~ :;records Attome} I.D. ~los. 212~Sf3I5816 .411vrneysfor PlainJi[~5, ~ ~ ~`~~-y;.~~~ ~ ~ . 24 G. Markct Street 1'.O. Box 565 Wcst Chester. PA 19381-0565 JOI~ATE-IAN THORSON and IN THE COURT OF COM14]ON PLEAS GRACE SONG, PHILADEZPHI.4 COUNTY, PA Plaintiffs, No. 0I451 MARCH TERM, 2019 EDDW, LLC, $I7DW DESIGN, LLC BDDW STUD1O, LLC, vi. CROW L[,C, TYLER HAYS, GARRETi' McGLOTHLIN, ERIC ANDERSpN and JACK SHELTOI~l, Defendants. PRAECIPE TO ENTE~t FINAL ,NDGMENT TO THE OrFICE OF JUD1C[AL RECORDS: Kindly enter judgment in favor of Plaintiffs, Jonathan Thorson and Grace Sung, pt~rsaant to the Order entered .lUty 6, 2022, attached hereto as Exhibit "A", folIowing the denial of Defendants' Motions for Post-Trial Relief, by Order entered October 31, 2022, attached hereto as Exhibit "B". Specifically: I. Enter judgment in favor ofPlaintif~, Jonathan Thorson, and against EDDW, LLC; BdDW DESIGN, LLC; BDDW STUDIO, LLC; M. CROW, LLC; and TYLER HAYS a/k/a TED TYLER HAYS, Defendants, in the amount of $8{14,3 i 3. i 0, plus interest from J aty 6, 2022, pEus cflsts, and; 2. Enter judgment in favt~r of Plaintiff, Grace Song, and against EDDW, LLC; BDDW DESIGN. LLC; BDDI~' STUDIO, i.LC; M. CROW, LLC; and TYLER HAYS a/ic/a TED 'TYLER ~-[AYS, Defendants. in the arnoant of $1,29b,469.65, plus interest from 3uly 6, 222, pius costs. ThS.s is a copy o£ a pleading filed electronically pursuant to New York State coart rules (22 Case ID: J.90301451 NYCRR §202.5-b;d)(3){i)) xhich, at the tis~ o£ its printout from the court system's electronic xebsite, had not yeC been xevieWed and approved by the County Clerk. Because court rules (22 NYCRR'§2fl2.5[d]) author;zQ the County Clezk to Filings for various reasons, readers should be aware that documents bearing this legend may not have rajaet been accepted foz filing by the County Clerk. 3 pf 51 3 of 52 FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023 LFTLED: NEW YORK COUNTY CLERK 03 23 2023 09 • Sl AM INDEX NO. 152683/2023 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 06/13/2023 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/23/2023 CAUTION: T~tIS DOCUMENT yAS NOT YET BEEN REVIEWED gy THE COUNTY CLERIC. jSoo be].oK. ) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 1 RECEIVEQ NYSCEF: Q2/21/2023 In addition, please index the judgment in the ,fuclgment Index pursuant to Rule 302 t. LAND McERLANE PC Dated:lanuary 17, 2022 By. ~ev C. Zu~ftlitu~to- George C, Zumbaao Jake A. Bec,~cer ~Qttorneysfor Plaintiffs Case ID:i9Q3a1451 This is a copy of a pleading Eiled electronically pursuant to Nev York State court rules (22 NYCRR §202.5-b(d}(3)ji)) which, at the time of its pra.ntout from the court ayatem's eiectroniC wWszte, had not yet bo.n raviawad and approved by the County Clack. Because coazt rules (22 NYCRR §202.5[dj) suthorisa tha County Clerk to reject filings !or vaxious reasons, readers should be aware that documents bearing thin legend may not have been accepted for filing by the County Clerk. 4 of SJ. 4 of 52 FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023 [FILE,D: NEW YORK COUNTY CLERK 03 23 2023 09:51 AM INDEX NO. 152683/2023 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 06/13/2023 NXSCEF DOC. NO. 2 RECEIVED NYSCBF: 03/23/2023 CAUTION; THIS pOC1TMENT HAS NOT YET BEEN REVIEWED SX T&E COUNTY CLERK. ~8ee below.) TNDEX N0. UNASSIGNED NYSCEF DOC. H0. 1 RECEIVED NYSCEF: 02/21/2023 LAMB McERLAI~tE PC By: Gcorge C. Zumbano lake D. Becker Attorney I.D. Nos. 21295/3! 5818 Alrorneys jor Plcrn~~(fs 24 E. Markct Street P.O. Box 565 West Chester, PA 19381-0565 JONATHAN TF-iORS~N and IN THE COURT OF COMMON PLEAS GRACE SONG, PHILADELPHIA COUTI'1'Y, PA Piaintiff5, No. 0145 I MARCH TERM, 2019 v. EDDW, LLC, BDDW DESIGN, LLC BDDW STUDIO, LLC, M. CROW LLC, TYLER HAYS, GARRETT McGLOTHLIN, ERIC ANDERSON and JACK S[dELTON, Defcndants. CERTIFICATE OF SERVICE This is to certsfy that in this case, complete copies of al l papers contained in the foregoing PrQecipe to Enter F;na! Judgment was served upon the following by the following means and on the date stated bolow: Name: Means of Service: Date of Service' Jeffrey J. Clarlaato, Esquit~e via emgi~ -JefJ~bdd~r.to~ 7anuary t7, 2023 Katclyn A. Feldstein, Esquire and kfeTdrteinQbddiv.com 3801 Jasper Street and First Class Ma!! PhiEadelphia, PA 19124 David M. PromislaiF, Esquire t~ia email -je,~t bddiv,COdi Promislof~'Law PC aid First Class Mail 5 Great Valley Parkway, St. 210 Malvern, YA 79355 LAMB McERLANE PC By: Gear,-- C. Zu.,n~ia~to- George C. Zumbano Jake D. Becker Attorneysfor Plaint This is a copy of a pleading Filed electronically parsuant Lo Nea York State court zu].es (22 NYCAR Case ID:1903U1.451 §202.5-b(d)(3j(i)) which, at the time of zts printout from the court system's electzonic website, had nat yat been reviewed and approvQd by the County Clerk. Because court xules (22 NYCRA §202.5[d]y authorize the Cavnty Clerk to reject filings for various xeasons, readers should be aware that documents bearing thin legend may nod have been accepted far filing by the County Clerk. 5 0~ 51 5 of 52 FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023 FILE: NEW YORK COUNTY CLERK 03 23 2023 Q9:51 AM INDEX NO. 152683/2023 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 06/13/2023 NYSCEF DEC. NO. 2 RECEIVED NYSCEF: 03/23/2023 CAUTION: THIS DOCIII~NT HAS NOT YET BEEN REYZ$WEp SY TAE COONTY CLERIC, (See balax.) INDEX NO. UNASSIGNED NYSCEF DOC. N0. 1 RECEIVED NYSCEF: 0 2 /2 1/2023 ~XH~BIT "A" Case ID: 190301.451 This ie a copy of a pleading filed electronically pursaant to Nex York State court rules (22 NYCRR §202.5-b(d)(3}(1J) xhSch, at the time of its printout from the Court syatmt's electzonic xebsita, had not yeL been reviewed and approved by tAo County Clerk. Seeause coart rules (22 NYCRR $202.5[dJ) authori.za Cho County Clark to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been acceQted for filing by the County Clerk, 6 of SZ b of 52 FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023 [FILED: NEW YORK COUNTY CLERK 03 23 2023 09:51 AM INDEX IVO. 152683/2023 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 06/13/2023 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/23/2023 CAUTION: THZS DOCUN~NT HA$ NOT YET BEEN REVIEWED 8X T&E COIINTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 1 RECEIVED NYSCEF; 02/ZI/2023 JONATHAN THdRSON and GRACE SON G COURT OF ~OMMQN PLEAS Pf{iLADELPHlA COUNTY Alaintiffs MARCH TERM, 2U19 v. NO.01451 EDDW, LLC. BDDW DESIGN, !.l,,~ BDDW STUOTO, [,LG M. CROW Ll.C, TYLER HAYS, GARRETT McG1.QTHLITI, ERtC ANDERSON and ]ACK SHELTON. Defendanl(s) ORDER ,¢" AND NOW this ~l} day of 3uly 2022, in consideration o€the foregoing Finding of Fact and Conclusions of I.aw, the Court fends in favor of PIaindffs, Jonathan Thorson and Grace Song, and against Dcfendanis, EDDW, LLC, BDDW Design, LLC, BDDW Studio. LLC, M. Crow LLC, and Tyler Hays. The Court finds that Fiaintiff, Jonathan Thorson, is entitled to 2% of the Defendants' valuation of the business pies, as;iquidated damages, an amount egos[ to twenty-eve percent (25%) of the total amount of wages due, which gives a total amount of X864,313.1Q. The Court finds that Plaintiff. Cfrace Song, is entitled to 3% of Defendants' valuation of the business plus, as liquidated dacnagts, an amount equal to twenty-five percent (2S%) of the fatal amount of wages due of $1,296,469.65. This is a copy of a pleading filed electronically pursuant to Neu York Slate court rules (22 NYCRR Case ID:19O3Q1451 §202.5-bid)(3)~i)y which, at the time of its printout from the court system's electronic vahsi.ta, had not yet been reviewed and appzoved by the County C1ezk. Because court rules (22 NYCAR §202.5(dJ) authozize the County Clerk to reject filings for various reasons, readers should be axare that documents bearing this legend may not have been accepted for filing by the Caanty Clerk. '7 Of S1 7 of 52 FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023 FILED: NEW YORK COUNTY CLERK 03 23 2023 Q9:51 AM INDEX NO. 152&83/2023 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 06/13/2023 NYSCEF DOC. NO. 2 RECEIVEp NYSCEF: 03/23/2023 CAUTION: THIS DQCI)MENT HAS NOT YET BEEN REVIEWED 8Y THE CAUNTY CLERK. (3ee below.) INI3EX NO. UNASSIGNED NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/21/2023 The Court finds that Plaintiff s counsel is entitled to attorney's cost and foes.' ludgmwat is entered is favor of Plaintiffs, Jonathan Thanaa and Grace Song. and against Defendants, EDDW, LLC, BDDW Design, LLC, BI~AW Studio. LI~C, M. Crow LLC, $nd Tyler Hays. BY THE COURT: .~ J. 1 Plaintiff's t0un5ef Is to su6mlt a post-rerd9ct petition explalning theireosts and Fees incurred to relation to the present matter. This xa a copy of a pleading £i.7.ed electronically pursuant to N¢x York State court rules (22 NYCRR $202.5-b(d)(3y(iy} Case ID:190301451 which, at the time of its printouC from Che court system's electronic websiLe, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR $202.S~dj) authorize the County Clerk to reject filings for vazious reasons, reade=a should be aware that documents bearing this legend may not have been accepted for filing by the County Clezk. g pf 51 8 of 52 FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023 FILED: NEW YORK COUNTY CLERK 03 23 2023 09:51 NYSCEF DOC. NO. 2 AM INDEX NO. 152683/2023 RECEIVED NYSCEF: 06/13/2023 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/23/2023 CAUTION: THIS DOCVl~NT gAS NOT YET SEEN RBVIE9iED BY T~ COUNTY CLERIC. {SEC below.) INDEX NQ. UNASSIGNED NXSGEF D0C. NO. 1 RECEIVED NXSCEF: 02/21/2023 EXH ~SIT "~" Case ID:190301451 This ie a copy of a pleading filed electronically pursuant to Kew York State court rules (22 NYCRA 5202.5-b(d)(3?(i)) which, at the time o~ its printout Erom the court eystwn's electronic Mebane, had nat yet been reviexed and approved by the County Clerk. Because court rules (22 NYCRR §20T.5[d]) authorize the County Clerk to reject filings #or various reasons, readers should bo axase that dooumenta bearing thio legend may not bane bean accepted Eor filing by the County Clerk. g of 52 9 of 52 FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023 [FILED: NEW YORK COtTNTY CLERK 03 23 2023 09:51 AM I~mEx NO. 152683/2023 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 06/13/2023 NYSCEF DOC. IVO. 2 RECEIVED NYSCEF: 03/23/2x23 CAiITION: THIS DOCfTMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLER3C. (See below.) INDEX NO. UNASSIGNED I~itSCEF DOC. NO. 1 ___. 3 JONATHAN THORSflNand GRACE SONG COURT OF COMMON PLEAS PHILADELPHIA COUNTY Plaintiffs MARCH TERM, 2Q19 v. . NO.0I45 i EDDW, LLC, BDDW DESIGN, LLC BDDW SNDIO, LLC, M. CROW LLC, TYLER HAYS, GARRETT McGLOTHLIN, fiRIC ANDERSON and .TACK SHEL"PON, , Qefendant(s) ORDER AND NOW, on taus 31~ day of October 2422, upon consideration of Defendants', EDDW, LLC., BDDW Design, LLC., $DDW StucEio, LLC., M. Crow, LLC., and ~Fyler Hays, Motion for Post-Trial Relief gurs~aai to PA.R.C.P.227.I, aad any response thcreto~ zt is hereby ORDERED and DECREED that nefiendants' Motion is DENIED. $Y r~ covRx: T is is a copy of a Qleadiag £fled electronicaily pursuant to Neer York State court rules (22 NYCRR Case ID: 190301451 v ich, at the time of ita printout from th¢ court 9y9tG16'9 e].ectroaic website, had not yet y202.5-b(d){3)(i)) been reviewed and a proved by the County Clerk. Because court rules (22 NYCRR 5202.SjdJ)._authorxze the County Clerk to zeject filinga £or various zeasons, zeader~ should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. ]D Of 51 io of sa FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023 FILED: NEW NYSCEF DOC. NO. 2YORK COUNTY CLERK 03 23 2023 09:51 AM INDEX NO. 152683/2023 RECEIVED NYSCEF: 06/13/2023 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/23/2023 CAUTION: TFIIS DOCUt~NT HAS NOT YET HEEN REVIEWED SY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/21/2023 JO1~EATHAN THORSON and ItJ THE CURT OF CQMMON PLEAS GRACE SONG, PHILADELPHIA COUNTY No. i9-Q3-0fl1451 Plaintiffs, MARCH TERM, 2Q19 v. EDDW, LLC, SDDW DESIGN, LLC JURY TRlA~ DEMAl~iD6D BDDW STUDIO, LLC, M. CROW LLC, TYLER HAYS,GARRETT McGi,OTHLIN, ERIC ANDERSON and JACK SH~LTON, Defendants. JITDGMENT ,,~ On this day of ,ianuary, 2423, JUDGMENT is entered: 1. in favor of Jonathan Thorson and against EDDW, LLC; BDDW DESIGN, LL,C; BDDW STUDIO, L[.C; M. CROW, LLC; and TYLER HAYS a/k/a TED TYLER HAYS, an the amount of $Sb4,313.10, plus interest from 3uly 6, 2022, plus costs; and 2. 1n favor ofGrace Song and against EDDW, LLC; BDDW DESIGN, LLC; SDDW STUDIO, LLC; M. CROW, LLC; and TYLER HAYS aJkla TED TYLER HAYS, in the amount $1,24b,469.65, plus interest ~6~om )uly 6, 24 2, plus costs. OFFICE OF .RJDICIAL RECORDS By: Case ID:1~0341451 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §2D2.5-b(d)(3)(i)) which, at tha time of its printout from the court syecem's electronic website, had not yeC been reviewed and appzoved by the County Clerk. 9eaause eaurt rules (22 NYCRR §202.5[dj) authorize the County Clerk to reject filings for various reasons, readers should be aware that doeumeets bearing thza legenfl may not have been accepted for filing by the County C.Ierk. ~~ Of S1 11 of 52 FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023 FILED: NO. 2YORK COUNTY CLERK 03 23 2023 09:51 NYSCEF DOC. NEW INDEX NO. RECEIVED NYSCEF: 152683/20 23 06/13/2023 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/23/2023 CAUTION: THIS DOC[JMERT HAS NOT X£T SEEN REVIEWED HY THE COUNTY CLLAK. (See below.) =NDEX NO. UNASSIGNED NXSCEF DOC. NO. 1 RECEIVED ATXSCEF: 02/21/2023 LAMB i41cERLAiVE PC By: George C. Zumbano Jake D. Beckcr Attorney I.D. T2o5. 21295/315818 ~Itrorneysjnr Plalnr~ 24 E. Market Street P.O. Bos 565 West Chester, PA 19381-0565 JO~tATHAN THORSON and IN THE COURT OF COMMON PLEAS GRACE SONG, FI~iILADELPHJA COUNTY, PA PIaintiffs, No. ~ 1451 MARCEt TERM, 2019 v. EDDW, LLC, $bDW DESIGN, LLC BDDW STUDIQ, LLC, M. CRAW LLC, TYLER HAYS, GARRETT McGLOT1-ILW, ERlC ANDERSON ar~d JACK SHEi.TON, Defendants. NOTICE PURSUANT TO Pa.R.C.P 236 TO: EDDW,LLC BDDW RESIGN, LLC $DDW STUDIO, LLC 3801 Jasper Street 3801 Jasper Street 3801 Jasper Street Philadelphia, PA 39124 Phi lade~phia, PA 19124 Pfuladelph9a, PA 19 [2~ lYT. CROW LLC TXLER HAYS a/k/a 3801 Jasper Street TED TYLER HAYS Pt~iladetphia~ PA 19124 3801 Jasper Street Phi[adeiphia, PA 1924 YOU ARE HEREBY NOTIFIED THAT .TiJDGMENT HAS BEEN ENTERED AG.~irlST' YOU AND IN FA'VUR U~ TAE F~LLLWING PARSONS IN THE FOL~OWWG AMOUNTS: Judgment has been entered in favor of Plaintiff, Jonathan Thorson, and againstthe above- named J~efendants in the amount of 5864,313.10, plus interest from July 6, 2022, plus costs. Judgment has been entered in favor of Plaintiff, Grace Song, and against the above-named Defendants in the amount of $1,296,469.65, plus interest from July b, 2022, plus costs. DATE: OFFICE OF JUDICIAL RECORDS This is a copy of a pleading EiJ.ed electronically pursuant to New York State courC Case ID:190301451 Which, at the time of its printout Eram the Court system's electronic webaite, rules (22 NXCRR 5262.5-bid)(3){iy) had not yet been reviewed and approved by the County Clerk. Because courk zvles (22 NYCRR §202.5(d]) authorize the County Filings for various =ea~ons, =coders should be aware that doceunents bearing this Clerk to reject accepted for filing by the County Clerk. legend may not have been 12 OF S1 22 of 52 FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023 FILED: NEW NYSCEF DOC. NO. 2YORK COUNTY CLERK 03 23 2023 09:51 AM INDEX NO. 152683/20 23 RECEIVED NYSCEF: 06/13/2023 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/23/2023 CAOTION: THIS DOCUMENT flAS NOT Y£T BEEN REVIEWED BY THE CO[FT1TY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. N0. 1 RECEIVED NYSCEF: 02/21/2Q23 LAMB Mc~12LAiVE PC By: Gcorge C. Zumbano Iake D. Becker Attorney I.D. Nos. 212951315818 Attorneysfor Plaint 24 E. Market Street P.O. liox S65 West Chester, PA 193$1-0565 .f ONATHAN 'FHORSON and ITV TIC COURT OF COMMON PLEAS GRAC£ SONG, PHILADELPHIA GOi1NTY, PA Plaintiff's, No. 0 f X51 MARCH TERM, 2019 v. EDDW, LLCMBDDW DESIGN, LLC BDDW STUDIQ, LLC, M. CROW LLC, TYLER HAYS, GARRETT McGLOTHLfItiT. ERiC ANpERSON and JACK SHELTON, Defendants. CERTIFICATTON ~F ADbRESSES I hereby certify that the following are the addresses of the fallowing Defendants: EDDW, LLC BDDW DESIGN, LLC BDDW STUDIO, LLC 3801 Jasper Street, 38~I Jasper Street, 3801 Sasper Street Philadelphia, PA 19124 Philadelphia, PA 19124 Philadelphia, PA 19 [24 M. CROW LLC TYLER HAYS alk/a 3501 Jasper Street, 'FED TYLER HAYS Philadelphia, PA 19124 3801 ]riper Street Philadelphia, PA 19125 LAMB McERLANE PC Date: January 17, 2Q23 By: ~.or~,~iC. Zuan~tu2o- George C. Zumbana Jake D. Becker Attorneys,for Plaintiff This is a copy of a pleading filed electronically pursuant to New Yozk State Case ID: 19O3O1451 which, nt the time of its printout From the court system's electronic webaite, court rules (22 NYCRA $202.5-bid?(3)(i)) had not yet been revfexed and approved by the County Clerk. Because court rules (22 NXCRR §2Q2.S(d1} autk~orize the County C2ezk to reject #flings for various seasons, readers should be ar,+a=e that documents bearing this legend may not have been accepted for filing by the County Clezk. 'E3 Of 51 13 of 52 FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM INDEX NO. 155313/2023 FILED: NEW NYSCEF DOC. NO. 2YORK COUNTY CLERK 03 23 2023 09:51 AM INDEX NO. 152683/2023 RECEIVED NYSCEF: 06/13/2023 NYSCEF D0C. N'0. 2 RECEIVED NYSCEF: 03/23/2023 CAUTION: THIS DOCUMENT HAS NOT YET SEEN REVIEWED HY THE COUNTX CLERK. (See below.} INDEX N0. UNASSIGNED NYSCEF D0C. NO. 1 RECEIVED NYSCEF: 02/21/2023 Page 1 First judicial aistricE of ~'ezu~sylvania ~ 'Z'3aia1 Division-Civil DC)CI~TREPORT CASE I~i7MBER CASE CAP7TON .-. ..^ ~ "` "'`""~ ~~8 T̀~ 19~301451 ZT~ORS(3NE'I'AL'VSEDDW,LLCE7'AL FXT.kNG DATE: 12MAR2019 CURT: M1 JURY: N CASE TYPE: CON'FTiACTS O'[~iER STATUS: ~iJDGMENT ON COURTS FiNDiTiG SLATED CASES: Events; • Bver+ED~iption Schedule .~-, Room! judge Name '~ 5 DatQJXsme '` ~~- <~ocation ;y` :.. ::~ MO'~ON HEA,~tING ~S-FEB-73 ~ COURTitOOM 2B5! JOHNSON, VIl1iCENT L ~9.3~Q0.~ ,,CPIYHALL ~ `~;;a. Seq. No. Assoc Exprahon~ ~r,`~.~~azty; ~~. t~,.XD:~ ~ '~~PartvName/Address 1 GEORGE C BT ST PA I9381 ~"°~6I0)692-0ff77-FAX xizmbanoC~Iambma~rlane.aom 2 1 PLF _ ~1QS974t9 THOILSON, JONATHAN 28,30 GREEI~E ST I.TI~TPI' 5E NEW YORK, NY 10013 3 24 DFT ~105974Z0 SF~EL~ON, jAQC 1T25 MARLBOROUGH ST PL~IILADELPHIA, PA 19725 4 1 PLF X10597421 SONG,GRACE 818N 4TH S~' UIJIT 3B PHILADELPHIA, PA I9323 5 ]3 DFI' ~1U597422 EDDW LLC asozJ~~xsr .,-.~- PHiLAD~LPHL~, PA ~;`~~, 6 13 X}kT X10547'473 BDDWDESIGNLLC ~~i~si,'` `~~ 38QI~ASPQZST ~.;~~~~ , ,. ~.. ~•. PHILADELPHIA., PA 1 c~ oa/iir OB-F~-192] Q9 ~56:]O A133=9739 c7[i' Thzs is a copy of a pleading filed electronically pursuant to New York State court rules {22 which, at the time of ita p=iatout Erom the court system's electronic xebsite, had not yet NYCRA §202.5-b(d}(3}(i)) been reviewed and approved by the County Clerk. Bocause count rules (22 NYCRA §202.5[d]) auhhoriza tho County Clerk'to filings for various reasons, readers should be aaaare that documents bearing this .legend may not reject accepted for filing by the CounCy Clerk. have been ~q Of 51 14 of 52 FILED: NEW YORK COUNTY CLERK 06/13/2023 02:19 PM