On July 18, 2023 a
Exhibit,Appendix
was filed
involving a dispute between
Corporate Solutions Group I, Llc
Dba Csg Partners, Llc,
Csg Bsh Partners Iii, Llc,
Csg Real Estate Partners, Llc,
Csg Re Partners, Llc,
and
Birds Fountains Forestwood Llc,
Birds Investments, Inc.,
Copper Ridge Apartments, Llc,
Daniel Blumkin,
Ian Behar,
Magnolia Trace Apartments, Llc,
Ryan Sasson,
Timberline 1042 Management Inc.,
for Commercial - Other - Commercial Division
in the District Court of New York County.
Preview
INDEX NO.
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 07/18/2023
SUPREME COURT OF THE STATE OF NEW YORK
3/2011
county oF New York J x Index No.
Corporate Solutions Group |, LLC d/b/a
CSG Partners, LLC, et al. RJI No. (if any)
-against- Plaintiff(s)/Petitioner(s)
lan Behar,et al. COMMERCIAL DIVISION
Defendant(s)/Respondent(s) Request for Judicial Intervention Addendum
COMPLETE WHERE APPLICABLE [add additional pages if needed]:
Plaintiff/Petitioner’s cause(s) of action [check all that apply]:
Breach of contract or fiduciary duty, fraud, misrepresentation, business tort (e.g. unfair competition), or statutory and/or common
law violation where the breach or violation is alleged to arise out of business dealings (e.g. sales of assets or securities; corporate
restructuring; partnership, shareholder, joint venture, and other business agreements; trade secrets; restrictive covenants; and
employment agreements not including claims that principally involve alleged discriminatory practices)
Oo Transactions governed by the Uniform Commercial Code (exclusive of those concerning individual cooperative or condominium
units)
Oo Transactions involving commercial real property, including Yellowstone injunctions and excluding actions for the payment of rent
only
(11 Shareholder derivative actions — without consideration of the monetary threshold
Oo Commercial class actions — without consideration of the monetary threshold
Oo Business transactions involving or arising out of dealings with commercial banks and other financial institutions
Oo Internal affairs of business organizations
Oo Malpractice by accountants or actuaries, and legal malpractice arising out of representation in commercial matters
Oo Environmental insurance coverage
Oo Commercial insurance coverage (e.g. directors and officers, errors and omissions, and business interruption coverage)
oO Dissolution of corporations, partnerships, limited liability companies, limited liability partnerships and joint ventures — without
consideration of the monetary threshold
Oo Applications to stay or compel arbitration and affirm or disaffirm arbitration awards and related injunctive relief pursuant to CPLR
Article 75 involving any of the foregoing enumerated commercial issues — without consideration of the monetary threshold
Plaintiff/Petitioner’s claim for compensatory damages [exclusive of punitive damages, interest, costs and counsel fees claimed]:
17,000,000
$
Plaintiff/Petitioner’s claim for equitable or declaratory relief [brief description]:
Plaintiffs seek a permanent injunction against future misuse and disclosure of intellectual property in violation of the
parties’ non-disclosure agreements.
Defendant/Respondent’s counterclaim(s) [brief description, including claim for monetary relief]:
| REQUEST THAT THIS CASE BE ASSIGNED TO THE COMMERCIAL DIVISION. | CERTIFY THAT THE CASE
MEETS THE JURISDICTIONAL REQUIREMENTS OF THE COMMERCIAL DIVISION SET FORTH IN 22 NYCRR §
202.70(a), (b) AND (c).
Date
gq: 7/18/2023 /s/ Gabriel Hertzberg
ee
SIGNATURE
Gabriel Hertzberg
PRINT OR TYPE NAME
lof 1
Document Filed Date
July 18, 2023
Case Filing Date
July 18, 2023
Category
Commercial - Other - Commercial Division
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INDEX NO. NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 07/18/2023 SUPREME COURT OF THE STATE OF NEW YORK 3/2011 county oF New York J x Index No. Corporate Solutions Group |, LLC d/b/a CSG Partners, LLC, et al. RJI No. (if any) -against- Plaintiff(s)/Petitioner(s) lan Behar,et al. COMMERCIAL DIVISION Defendant(s)/Respondent(s) Request for Judicial Intervention Addendum COMPLETE WHERE APPLICABLE [add additional pages if needed]: Plaintiff/Petitioner’s cause(s) of action [check all that apply]: Breach of contract or fiduciary duty, fraud, misrepresentation, business tort (e.g. unfair competition), or statutory and/or common law violation where the breach or violation is alleged to arise out of business dealings (e.g. sales of assets or securities; corporate restructuring; partnership, shareholder, joint venture, and other business agreements; trade secrets; restrictive covenants; and employment agreements not including claims that principally involve alleged discriminatory practices) Oo Transactions governed by the Uniform Commercial Code (exclusive of those concerning individual cooperative or condominium units) Oo Transactions involving commercial real property, including Yellowstone injunctions and excluding actions for the payment of rent only (11 Shareholder derivative actions — without consideration of the monetary threshold Oo Commercial class actions — without consideration of the monetary threshold Oo Business transactions involving or arising out of dealings with commercial banks and other financial institutions Oo Internal affairs of business organizations Oo Malpractice by accountants or actuaries, and legal malpractice arising out of representation in commercial matters Oo Environmental insurance coverage Oo Commercial insurance coverage (e.g. directors and officers, errors and omissions, and business interruption coverage) oO Dissolution of corporations, partnerships, limited liability companies, limited liability partnerships and joint ventures — without consideration of the monetary threshold Oo Applications to stay or compel arbitration and affirm or disaffirm arbitration awards and related injunctive relief pursuant to CPLR Article 75 involving any of the foregoing enumerated commercial issues — without consideration of the monetary threshold Plaintiff/Petitioner’s claim for compensatory damages [exclusive of punitive damages, interest, costs and counsel fees claimed]: 17,000,000 $ Plaintiff/Petitioner’s claim for equitable or declaratory relief [brief description]: Plaintiffs seek a permanent injunction against future misuse and disclosure of intellectual property in violation of the parties’ non-disclosure agreements. Defendant/Respondent’s counterclaim(s) [brief description, including claim for monetary relief]: | REQUEST THAT THIS CASE BE ASSIGNED TO THE COMMERCIAL DIVISION. | CERTIFY THAT THE CASE MEETS THE JURISDICTIONAL REQUIREMENTS OF THE COMMERCIAL DIVISION SET FORTH IN 22 NYCRR § 202.70(a), (b) AND (c). Date gq: 7/18/2023 /s/ Gabriel Hertzberg ee SIGNATURE Gabriel Hertzberg PRINT OR TYPE NAME lof 1