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STATE OF MICHIGAN CASE NO.
JUDICIAL DISTRICT AFFIDAVIT AND NOTICE OF ENTRY -CB
3rd JUDICIAL CIRCUIT OF FOREIGN JUDGMENT
Court address Court telephone no
2 Woodward Ave, D ‘oit, MI 48226 313-224-5261
Judgment creditor's name, address, and telephone no | Judgment debtor's name, address, and telephone no.
Global Merchant Cash, Inc. | Dix Automative Recycler, Inc. d/b/a Dix Automotive
| Recycler, and
| Najlah Abdallah Ismail
3298 Dix Highway
| Lincoln Park, MI 48146
|aaginent creditor's attorney, bar no., address, and telephone no. Judgment debtor's aliorney, bar no., address, and telephone no
Corey D. Silverstein (P696 )
Navjyot Francis (P72322)
Silverstein Legal |
30150 Telegraph Road, Suite 444 ||
|
Bingham Farms, MI 480: (248) 290-0655
— . - - . J | a
—
[AFFIDAVIT
lam thejudgment creditor of the attached authenticated foreign judgment, which is being filed so that it may be enforced and satisfied
in this state. The addresses above are the last-known addresses of the judgment creditor and the judgment debtor.
I
——
[Name of state where foreign judgment was issued Name of court that issued foreign judgment Case number “Amount of judgment®
| New York Supreme Court, County of Kings 518958/2021 $107,172.98
|
Date of judgment
|
|
May 5, 2023 Sa
_ 4 a
“The amount of judgment does not include interest. Judgmept crediigr/Atiomey signature
Subscribed and swornto beforeme on I2O_ |22 ee CE A klancl He te Ge fe ican
Co fs gnd state of glher jurisdiction
where acti 3
My commission expires: T | “ 2] 27% Signature: Le Lf Cihbcd= LOD el —
Notary public. Oa
County and state fC other
bake of Michigan
TaSdicton where cbmmissioned
LORI-ANNE F. WOOD
NOTARY PUBI LIC - STATE OF MIC
HIGAN
i COUNTY OF OAKLAND
i NOTICE
a OF ENTRY | | My Commission Expires
‘Acting in the County of
The authenticated foreign judgment is accepted for filing. Enforcement may begin 2’ ne oe of the filing of the
foreign judgmentis mailed
This document must be sealed /s/ Linda Woods 7/25/2023
a — by the seal of the court. — —
Date Court derk
A
[ CERTIFICATE OF MAILING |
wo
\ certify that on this date | served a copy of this affidavit and notice on the parties or their attorneys by first-class mail addressed to
their last-known addresses as defined in MCR 2.107(C)(3).
a — a —
Date Signature
Mc 62 (3/08) AFFIDAVIT AND NOTICE OF ENTRY OF FOREIGN JUDGMENT MCL 691.1171 et seq.
No. 4670442
THE PEOPLE OF STATE OF NEW YORK
BY THE GRACE G OD FREE AND INDEPENDENT
To all to whom these Presen y come, GREETING:
OW YE : That we have inspected the files and records in the
ffice of the Clerk of the County of Kings, at Brooklyn, in said
ounty, and do find a certain
Index 958/2021, Judgment, Filed 05/05/2023
remaining there on file or on record in the words and figures
following, to wit :
macs
<
No. 4670441
Certification
STATE OF NEW YORK, COUNTY OF KINGS, SS
|, Nancy T. Sunshine, County Clerk and Clerk of Supreme Court Kings County,
do hereby certify that on May 8, 2023 | have compared
the document attached hereto
Index# 518958/2021, Judgment, Filed 05/05/2023 page(s) 1-4
with the originals filed in my office and the same is a correct transcript
therefrom and of the whole of such original in witness
whereto | have affixed my signature and seal
Powe 4 2 harbor
vatgey T. SUNSHINE
KINGS COUNTY CLERK
er Ue ¥
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
ween
eee nne ene wate nn ene en nee
GLOBAL M HANT CASH, INC,, Index No. 518958/2021
(Rothenberg, I.8.C.)
Plaintiff,
JUDGMENT
-against-
DIX AUTOMATIVE RECYCLER, INC. d/b/a DIX
AUTOMOTIVE RECYCLER and NAJLAH
ABDALLAH ISMAIL,
Defendants
eee eee
WHEREAS, Plaintiff Global Merchant Cash Inc. (“Plaintiff”) commenced this action
against Defendants Dix Automotive Recycler Inc. and Najlah Abdallah Ismail (together,
“Defendants”) by the filing of the Summons with Notice (Dkt. No. 1) on July 29, 2021.
WHEREAS, service of process of the Summons with Notice was effected on each of the
Defendants on August 5, 2021 by certified mail, return receipt requested, in accordance with the
parties’ agreement. Dkt. Nos. 2 and 4
WHEREAS, on August 11, 2021, Antranig Garibian, Esq., filed a notice of appearance on
behalfof each of the Defendants and a demand for complaint. Dkt. No. 6.
WHEREAS, on August 16, 2021, Plaintiff served the Complaint. Dkt. No. 7
WHEREAS, on September 2, 2021, Defendants served an Answer. Dkt. No. 9
WHEREAS, by Decision and Order dated April 20, 2022, the Court (Rothenberg, J.S.C.)
granted Mr. Garibian’s motion to withdraw as counsel for Defendants and stayed the action for 60
days for Defendants to obtain new counsel. Dkt. No. 21
WHEREAS, on September 7, 2022, Plaintiff moved for a default judgment on the relief
sought in the Complaint against Defendants, which was unopposed by Defendants. Dkt. No. 29
11108546,1
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WHEREAS, by Order dated April 26 and entered in the Office of the Kings County Clerk
on May 3, 2023, the Court (Rothenberg, J.S.C.) ordered in relevant part as follows:
Accordingly, plaintiff's motion for summary judgment against the defendants is
granted on default. Plaintiffis awarded $91,784.04 plus interest from July 14, 2021,
plus costs and disbursements to be taxed by the Clerk of the Court upon submission
of appropriate bills of cost.
Upon submission of a copy of this order on the County Clerk, judgment shall be
entered accordingly.
Dkt. No. 47
NOW, upon the application of Carter Ledyard & Milburn LLP, attorneys for Plaintiff
Global Merchant Cash Inc., it is hereby
ADJUDGED that Plaintiff Global Merchant Cash, Inc., with an address at 64 Beaver Street,
Suite 415, New York, NY 10004, shall recover against Defendants Dix Automotive Recycler Inc
d/b/a Dix Automotive Recycler, with an address at 3298 Dix Highway, Lincoln Park, MI 48146,
and Najlah Abdallah Ismail, with an address at 3298 Dix Highway, Lincoln Park, M1 48146, jointly
and severally, in the amount of $91,784.04, with pre-judgment interest at the statutory rate of 9%
from July 14, 2021, in the amount of $_ $14,933.94 _, plus costs and disbursements herein
in the amount of $455.00, for a total judgment amount of $
$107,172.98 , and Plaintiff Global
Merchant Cash, Inc. shall have immediate execution therefor
Dated May. 5th 2023
Tg i
2 hurghkore
——
Clerk
FILED
2023 MAY 05 AM 9:49
KINGS COUNTY CLERK
FEE
11108546.
2 of
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
~ een nee ena ne ene eee
GLOBAL MERCHANT CASH, INC Index No, 518958/2021
(Rothenberg, J.S.C.)
Plaintiff,
BILL OF COSTS
-against-
DIX AUTOMATIVE RECYCLER, INC. d/b/a DIX
AUTOMOTIVE RECYCLER and NAJLAH
ABDALLAH ISMAIL,
Defendants
Costs ——
Proceedings before note of issue is filed - CPLR § 8201(1) 06
Disbursements
Index number fee cette $21 0
Motion filing fee (1)..
TOTAL BILL OF COSTS cessesssssessseeeeneseeesseneenes aseacacencassucaseeserenene sobvecesscsnseseenssveasesrenoecencsnsesee $455.00
The undersigned attorney for Plaintiff, duly admitted to practice in the courts of this state,
affirms that the foregoing disbursements have been or will necessarily be made or incurred on
behalf of Plaintiffin this action and are reasonable in amount. The undersigned affirms that the
foregoing statements are true, under the penalties of perjury.
Dated: May 4, 2023
CARTER LEDYARD & MILBURN LLP
FILED By /s/ Jacob H. Nemon
Jacob H. Nemon
2023 MAY 05 AM 9:49 28 Liberty Street, 41% Floor
New York, NY 10005
KINGS COUNTY CLERK Tel (212) 732-3200
Fax: (212) 732-3232
FEE
Email: nemon@clm.com
Attorneys for Plaintiff
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Court for said County to be hereunto
WITNESS, HON. Hon. Ropert Vv. Beery
& Justice of our Supresss
Court for the Second Jodieiel District of said State,
this
a? ao Vi.
20405
Ponty 2 dart
Clerk.
I, Hon. Rug a Justice of the Supreme Court
of the State of New York in and fo Basha Judicial District thereof, do hereby certify, that
Nancy T. Sunshine, whose name pscribed to the preceding exemplification, is the Clerk
of the County of Kings, and Cler| e Supreme Court in and for said County, and that full
faith and credit are due to her q acts
| FURTHER CERTIFY, tha eal affixed to said exemplification is the proper Seal of said
Court of said County, and th: attestation thereof is in due form of law and by the proper
officer.
WITNESS my hand Borough of Brooklyn,this
a3" “day of Gu in the year 20225
oS
nn M. Bom
A Justice of the Supreme Court of the State of New York
in and for the Second Judicial} District.
Hon. Rupert v, Barry
CPre. 4) 2 hur for
Clerk.
STATE OF NEW, }ss
County of K p }
1, NancyT. S je, Clerk of the County of Kings, and also of the Supreme Court of said
County in a’ the Second Judicial District of said State (said Court being a Court of
Record), do by certify, that Hon. Hon. Ru whose
name is $ bed to the foregoing certificat te4 isa Y-Aeati¢e of the Supreme Court of said State
in and econd Judicial District, duly elected and sworn, and that the signature of said
Certificate is genuine
'Y WHEREOF, | have hereunto set my hand and affixed the Seal of said County
23 day of Mes on. in the vear 20-7 5
4 2 bur eon
Clerk.
Department of Defense Manpower Data Center Results as of : Jul-19-2023 12:02:24 PM
SCRA 6.17
Status Report
Pursuant to Servicemembers Civil Relief Act
SSN: XXX-XX i
Birth Date: a
Last Name: ISMAIL
First Name: NAJLAH
Middle Name ABDALLAH
Status As Of: Jul-19-2023
Certificate ID 2QYDXHHLSBRYTTO
‘On Active Duty On Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA No. NA
This response reflects the individuals’ active duty status based on the Active Duty Status Date
Lefl Active Duty Within 367 Days of Active Duty Status Date
Active Duty Start Date ‘Active Duty End Date Status Service Component
NA NA No NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
‘The Memberor His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date
‘Order Notification Start Date ‘Order Notification End Date ‘Status Service Component
NA NA No NA
This response reflects whether the individual or his/her unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
Sam ousespgactal
Sam Yousefzadeh, Acting Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04625
Alexandria, VA 22350
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 3901 et seq, as amended) (SCRA) (formerly known as
the Soldiers’ and Sailors’ Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family
member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service. Service contact
information can be found on the SCRA website's FAQ page (Q35) via this URL: https://scra.dmdc.osd.mil/scra/#/faqs. If you have evidence the person
was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked
against you. See 50 USC App. § 3921(c).
This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1).
Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number
of protections of the SCRA
extend beyond the last dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
are protected
WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.