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CPM-L-000207-23 05/23/2023 5:33:59 PM Pg 1 of 14 Trans ID: LCV20231619275
FOX ROTHSCHILD LLP
Adam Busler (060762013)
Lauren A. Wright (305462020)
1301 Atlantic Avenue
Midtown Building, Suite 400
Atlantic City, New Jersey 08401
609-348-4515 (FAX: 609-348-6834)
Attorneys for Plaintiff,
JT Laundry CM LLC d/b/a the Laundry Dude
SUPERIOR COURT OF NEW JERSEY
JT LAUNDRY CM LLC D/B/A THE LAW DIVISION,
LAUNDRY DUDE, CAPE MAY COUNTY
Plaintiff, DOCKET NO.: ____________
v.
CIVIL ACTION
DESERT SAND RESORT
Defendant. COMPLAINT SUMMARY ACTION
Plaintiff, JT Laundry CM LLC d/b/a the Laundry Dude (“Laundry Dude”) by way of
Complaint says:
1. This is a summary action to compel arbitration arising from a breach of contract.
2. Laundry Dude is an entity with an address of 316 West Morning Glory Road, Fl. 2
Wildwood, New Jersey 08260.
3. Defendant Desert Sand Resort (“Desert Sand”) is a New Jersey business with an
address of 7888 Dune Drive Avalon, New Jersey 08202 (the “Property”).
4. On April 6, 2022, Laundry Dude and Desert Sand entered into a Contract (the
“Contract”) through which Laundry Dude would furnish, clean, pick up, and deliver various linens
at Desert Sand’s motel property located in Avalon, New Jersey. A true and correct copy of the
Contract is attached as Exhibit A.
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5. The Contract was negotiated and entered into in New Jersey.
6. Pursuant to the Contract, Desert Sand “agree[d] to rent all required merchandise
listed on [the] provided Price Sheet for initial installation and any additional merchandise required
thereafter exclusively from [Laundry Dude] . . . .” See Ex. A.
7. Pursuant to ¶11, the Contract was for a 36-month term commencing on April 12,
2022, the date of the first delivery. As such, the term of the Contract did not expire until April 11,
2025. See Ex. A.
8. After the execution of the Contract, Laundry Dude began the furnishing, cleaning,
pick up, and delivery of various linens at the Property.
9. Desert Sand unilaterally terminated the Contract on April 29, 2022.
10. At the time that the Contract was terminated, there was an outstanding balance of
$1,254.43 due and owing to Laundry Dude for services rendered prior to termination.
11. Paragraph 9 of the Contract provides:
RIGHTS OF CANCELLATION: Because it would be otherwise
difficult or impractical to fix the exact amount of damage to
[Laundry Dude], in the event that [Desert Sand] cancels this
[Contract] for any reason other than as described in paragraph 4,
[Desert Sand] will pay [Laundry Dude] 50% of the average weekly
dollar volume for the unexpired terms of the [Contract] based off the
average weekly business that is generated between [Desert Sand and
Laundry Dude] leading up to the cancellation. If [Desert Sand]
cancels this contract before a weekly average can be established,
[Desert Sand] will be required to pay to [Laundry Dude] on a weekly
basis, 50% of their total inventory at the price per piece that was
provided on the respective ‘Price Sheet.’ This monetary obligation
from [Desert Sand] to [Laundry Dude] is for the agreed upon life of
the [C]ontract.
See Ex. A.
12. There is presently an outstanding balance of $49,550.37 due and owing to Laundry
Dude.
2
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13. This balance is based on 50% of the average weekly dollar volume of the Contract
($627.22) times the unexpired term of the contract (154 weeks), in total a value of $48,295.94 plus
the unpaid balance for services rendered prior to termination. See Ex. A, ¶ 9.
14. Despite demand for payment, Desert Sand has not paid the $49,550.37, which
remains due and owing to Laundry Dude.
15. Therefore, a dispute has arisen between Laundry Dude and Desert Sand regarding
the payment due and owing under the Contract.
16. The Contract executed by Laundry Dude and Desert Sand contains an arbitration
provision that covers all disputes that arise under the Contract. See Ex. A, ¶ 12.
17. Specifically, ¶ 12 of the Contract states: “Any dispute in connection with this
[Contract] or any matter relating to this service agreement shall be resolved by binding and final
arbitration under the Federal Arbitration Act.” See Ex. A, ¶ 12.
18. On April 28, 2023, Laundry Dude sent Desert Sand, via email to counsel, a demand
for arbitration. A true and correct copy of the Arbitration Demand is attached as Exhibit B.
19. Despite due demand, Desert Sand has failed and/or refused to participate in the
arbitration process including the selection of an arbitrator.
20. Based upon the undisputed Contract provision, Laundry Dude is entitled to enforce
the arbitration provision contained therein.
21. In accordance with N.J.S.A. 2A:23B-7 and Rule 4:67, Laundry Dude is entitled to
move, by way of Summary Action, seeking an Order compelling Desert Sand to comply with the
dispute resolution provisions contained in the Contract.
WHEREFORE, Plaintiff JT Laundry CM LLC d/b/a the Laundry Dude demands judgment
compelling Defendant Desert Sand Resort to honor the dispute resolution provision contained in
3
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the Contract, together with costs of suit, reasonable attorney’s fees and any such other and further
relief the Court deems just and proper.
DESIGNATION OF TRIAL COUNSEL
Pursuant to Rule 4:5-1(c), Adam Busler, Esquire is designated as trial counsel on behalf
of Plaintiff JT Laundry CM LLC d/b/a the Laundry Dude.
CERTIFICATION PURSUANT TO R. 1:38-(b)
I hereby certify that confidential personal identifiers have been redacted from documents
now submitted to the court, and will be redacted from all documents submitted in the future in
accordance with Rule 1:38-7(b); (e) the foregoing statements made by me are true and correct to
the best of my knowledge, information and belief.
CERTIFICATION PURSUANT TO R. 4:5-1
I hereby certify that, to the best of my knowledge, the matter in controversy in this action
is not the subject of any other action pending in any court or of a pending arbitration proceeding,
nor is any action or arbitration proceeding contemplated at this time. I hereby certify that, to the
best of my knowledge, no parties should be joined in this litigation.
I hereby certify that the foregoing statements made by me are true. I am aware that if any
of the foregoing statements made by me are willfully false, I am subject to punishment.
FOX ROTHSCHILD LLP
Date: May 23, 2023 /s/ Adam Busler
Adam Busler
Lauren A. Wright
1301 Atlantic Avenue
Midtown Building, Suite 400
Atlantic City, New Jersey 08401
609-348-4515 (FAX: 609-348-6834)
Attorneys for Plaintiff,
JT Laundry CM LLC d/b/a the Laundry Dude
4
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EXHIBIT A
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EXHIBIT B
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Midtown Building
1301 Atlantic Avenue
Suite 400
Atlantic City, NJ 08401-7212
Tel (609) 348-4515 Fax (609) 348-6834
www.foxrothschild.com
ADAM BUSLER
Direct No: 609.572.2238
Email: ABusler@FoxRothschild.com
April 28, 2023
VIA EMAIL
Francis J. Ballak, Esquire
Goldenberg, Mackler, Sayegh, Mintz , Pfeffer, Bonchi and Gill
660 New Road, First Floor
Northfield, NJ 08225
Re: Service Rental Agreement between JT Laundry CM LLC d/b/a The Laundry Dude
and the Desert Sand Resort (“CUSTOMER”)
Dear Mr. Ballak:
My firm represents JT Laundry CM LLC d/b/a the Laundry Dude (“Laundry Dude”). I write to
demand arbitration pursuant to § 12 of the Service Rental Agreement (the “Contract”), dated April
6, 2022. A copy of the Contract is enclosed for your convenience.
Pursuant to the Contract, Laundry Dude agreed “to furnish, clean, and pick up and deliver” various
linens, including, but not limited to bed sheets, pillow cases, towels, and bath mats to the
CUSTOMER. By executing the Contract, CUSTOMER agreed that Laundry Dude is the sole
servicer of the items it provides to the CUSTOMER and that CUSTOMER was prohibited from
using any linen service provider without Laundry Dude’s express written consent during the term
of the Contract.
As you may recall, § 9 of the Contract provides:
Because it would be otherwise difficult or impractical to fix the
exact amount of damage to [Laundry Dude], in the event the
CUSTOMER cancels this [Contract] for any reason . . .,
CUSTOMER will pay to LD 50% of the average weekly dollar
volume for the unexpired term of the [C]ontract based off the
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April 28, 2023
Page 2
average weekly business that is generated between the
[CUSTOMER] and [Laundry Dude] leading up to the cancellation.
Pursuant to § 11, the Contract was for a 36-month term commencing on April 12, 2022, the date
of the first delivery. As such, the term of the Contract did not expire until April 11, 2025.
Our records indicate that the CUSTOMER unilaterally terminated the Contract on April 29, 2022.
As such, there were 141 weeks remaining on the Contract. Based on the CUSTOMER’s early
termination of the Contract, a total of $44,007.51 remains due and owing to the Laundry Dude.
This number is based on 50% of the average weekly dollar volume of the Contract ($627.22) times
the unexpired term of the contract (141 weeks).
CUSTOMER failed to respond to our letter dated September 8, 2022 demanding payment in
connection with the CUSTOMER’s early termination of the Contract.
Therefore, pursuant to § 12 of the Contract, the Laundry Dude hereby demands arbitration with a
local arbitrator under the Federal Arbitration Act. We propose the following arbitrators: Honorable
Michael A. Donio, J.S.C. (ret.), Honorable Francis J. Orlando, Jr., U.S.J. (ret.), or Honorable
James E. Isman, J.S.C. (ret.).
Should CUSTOMER fail to respond to this correspondence within ten (10) days, The
Laundry Dude will file a summary action with the Court to compel arbitration.
Please note that The Laundry Dude submits this letter without waiving any position, right, claim,
remedy or defense – all of which are expressly reserved.
Very truly yours,
Adam Busler
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TransID:
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LCV20231619275
Civil Case Information Statement
Case Details: CAPE MAY | Civil Part Docket# L-000207-23
Case Caption: JT LAUNDRY CM LLC VS DESERT SAND Case Type: SUMMARY ACTION
RESORT Document Type: Complaint
Case Initiation Date: 05/23/2023 Jury Demand: NONE
Attorney Name: ADAM BUSLER Is this a professional malpractice case? NO
Firm Name: FOX ROTHSCHILD LLP Related cases pending: NO
Address: 1301 ATLANTIC AVE SUITE 400 If yes, list docket numbers:
ATLANTIC CITY NJ 084017212 Do you anticipate adding any parties (arising out of same
Phone: 6093484515 transaction or occurrence)? NO
Name of Party: PLAINTIFF : JT Laundry CM LLC Does this case involve claims related to COVID-19? NO
Name of Defendant’s Primary Insurance Company
(if known): Unknown Are sexual abuse claims alleged by: JT Laundry CM LLC? NO
THE INFORMATION PROVIDED ON THIS FORM CANNOT BE INTRODUCED INTO EVIDENCE
CASE CHARACTERISTICS FOR PURPOSES OF DETERMINING IF CASE IS APPROPRIATE FOR MEDIATION
Do parties have a current, past, or recurrent relationship? NO
If yes, is that relationship:
Does the statute governing this case provide for payment of fees by the losing party? NO
Use this space to alert the court to any special case characteristics that may warrant individual
management or accelerated disposition:
Do you or your client need any disability accommodations? NO
If yes, please identify the requested accommodation:
Will an interpreter be needed? NO
If yes, for what language:
Please check off each applicable category: Putative Class Action? NO Title 59? NO Consumer Fraud? NO
I certify that confidential personal identifiers have been redacted from documents now submitted to the
court, and will be redacted from all documents submitted in the future in accordance with Rule 1:38-7(b)
05/23/2023 /s/ ADAM BUSLER
Dated Signed
Preview
CPM-L-000207-23 05/23/2023 5:33:59 PM Pg 1 of 14 Trans ID: LCV20231619275 FOX ROTHSCHILD LLP Adam Busler (060762013) Lauren A. Wright (305462020) 1301 Atlantic Avenue Midtown Building, Suite 400 Atlantic City, New Jersey 08401 609-348-4515 (FAX: 609-348-6834) Attorneys for Plaintiff, JT Laundry CM LLC d/b/a the Laundry Dude SUPERIOR COURT OF NEW JERSEY JT LAUNDRY CM LLC D/B/A THE LAW DIVISION, LAUNDRY DUDE, CAPE MAY COUNTY Plaintiff, DOCKET NO.: ____________ v. CIVIL ACTION DESERT SAND RESORT Defendant. COMPLAINT SUMMARY ACTION Plaintiff, JT Laundry CM LLC d/b/a the Laundry Dude (“Laundry Dude”) by way of Complaint says: 1. This is a summary action to compel arbitration arising from a breach of contract. 2. Laundry Dude is an entity with an address of 316 West Morning Glory Road, Fl. 2 Wildwood, New Jersey 08260. 3. Defendant Desert Sand Resort (“Desert Sand”) is a New Jersey business with an address of 7888 Dune Drive Avalon, New Jersey 08202 (the “Property”). 4. On April 6, 2022, Laundry Dude and Desert Sand entered into a Contract (the “Contract”) through which Laundry Dude would furnish, clean, pick up, and deliver various linens at Desert Sand’s motel property located in Avalon, New Jersey. A true and correct copy of the Contract is attached as Exhibit A. 145501851.2 CPM-L-000207-23 05/23/2023 5:33:59 PM Pg 2 of 14 Trans ID: LCV20231619275 5. The Contract was negotiated and entered into in New Jersey. 6. Pursuant to the Contract, Desert Sand “agree[d] to rent all required merchandise listed on [the] provided Price Sheet for initial installation and any additional merchandise required thereafter exclusively from [Laundry Dude] . . . .” See Ex. A. 7. Pursuant to ¶11, the Contract was for a 36-month term commencing on April 12, 2022, the date of the first delivery. As such, the term of the Contract did not expire until April 11, 2025. See Ex. A. 8. After the execution of the Contract, Laundry Dude began the furnishing, cleaning, pick up, and delivery of various linens at the Property. 9. Desert Sand unilaterally terminated the Contract on April 29, 2022. 10. At the time that the Contract was terminated, there was an outstanding balance of $1,254.43 due and owing to Laundry Dude for services rendered prior to termination. 11. Paragraph 9 of the Contract provides: RIGHTS OF CANCELLATION: Because it would be otherwise difficult or impractical to fix the exact amount of damage to [Laundry Dude], in the event that [Desert Sand] cancels this [Contract] for any reason other than as described in paragraph 4, [Desert Sand] will pay [Laundry Dude] 50% of the average weekly dollar volume for the unexpired terms of the [Contract] based off the average weekly business that is generated between [Desert Sand and Laundry Dude] leading up to the cancellation. If [Desert Sand] cancels this contract before a weekly average can be established, [Desert Sand] will be required to pay to [Laundry Dude] on a weekly basis, 50% of their total inventory at the price per piece that was provided on the respective ‘Price Sheet.’ This monetary obligation from [Desert Sand] to [Laundry Dude] is for the agreed upon life of the [C]ontract. See Ex. A. 12. There is presently an outstanding balance of $49,550.37 due and owing to Laundry Dude. 2 145501851.2 CPM-L-000207-23 05/23/2023 5:33:59 PM Pg 3 of 14 Trans ID: LCV20231619275 13. This balance is based on 50% of the average weekly dollar volume of the Contract ($627.22) times the unexpired term of the contract (154 weeks), in total a value of $48,295.94 plus the unpaid balance for services rendered prior to termination. See Ex. A, ¶ 9. 14. Despite demand for payment, Desert Sand has not paid the $49,550.37, which remains due and owing to Laundry Dude. 15. Therefore, a dispute has arisen between Laundry Dude and Desert Sand regarding the payment due and owing under the Contract. 16. The Contract executed by Laundry Dude and Desert Sand contains an arbitration provision that covers all disputes that arise under the Contract. See Ex. A, ¶ 12. 17. Specifically, ¶ 12 of the Contract states: “Any dispute in connection with this [Contract] or any matter relating to this service agreement shall be resolved by binding and final arbitration under the Federal Arbitration Act.” See Ex. A, ¶ 12. 18. On April 28, 2023, Laundry Dude sent Desert Sand, via email to counsel, a demand for arbitration. A true and correct copy of the Arbitration Demand is attached as Exhibit B. 19. Despite due demand, Desert Sand has failed and/or refused to participate in the arbitration process including the selection of an arbitrator. 20. Based upon the undisputed Contract provision, Laundry Dude is entitled to enforce the arbitration provision contained therein. 21. In accordance with N.J.S.A. 2A:23B-7 and Rule 4:67, Laundry Dude is entitled to move, by way of Summary Action, seeking an Order compelling Desert Sand to comply with the dispute resolution provisions contained in the Contract. WHEREFORE, Plaintiff JT Laundry CM LLC d/b/a the Laundry Dude demands judgment compelling Defendant Desert Sand Resort to honor the dispute resolution provision contained in 3 145501851.2 CPM-L-000207-23 05/23/2023 5:33:59 PM Pg 4 of 14 Trans ID: LCV20231619275 the Contract, together with costs of suit, reasonable attorney’s fees and any such other and further relief the Court deems just and proper. DESIGNATION OF TRIAL COUNSEL Pursuant to Rule 4:5-1(c), Adam Busler, Esquire is designated as trial counsel on behalf of Plaintiff JT Laundry CM LLC d/b/a the Laundry Dude. CERTIFICATION PURSUANT TO R. 1:38-(b) I hereby certify that confidential personal identifiers have been redacted from documents now submitted to the court, and will be redacted from all documents submitted in the future in accordance with Rule 1:38-7(b); (e) the foregoing statements made by me are true and correct to the best of my knowledge, information and belief. CERTIFICATION PURSUANT TO R. 4:5-1 I hereby certify that, to the best of my knowledge, the matter in controversy in this action is not the subject of any other action pending in any court or of a pending arbitration proceeding, nor is any action or arbitration proceeding contemplated at this time. I hereby certify that, to the best of my knowledge, no parties should be joined in this litigation. I hereby certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. FOX ROTHSCHILD LLP Date: May 23, 2023 /s/ Adam Busler Adam Busler Lauren A. Wright 1301 Atlantic Avenue Midtown Building, Suite 400 Atlantic City, New Jersey 08401 609-348-4515 (FAX: 609-348-6834) Attorneys for Plaintiff, JT Laundry CM LLC d/b/a the Laundry Dude 4 145501851.2 CPM-L-000207-23 05/23/2023 5:33:59 PM Pg 5 of 14 Trans ID: LCV20231619275 EXHIBIT A CPM-L-000207-23 05/23/2023 5:33:59 PM Pg 6 of 14 Trans ID: LCV20231619275 CPM-L-000207-23 05/23/2023 5:33:59 PM Pg 7 of 14 Trans ID: LCV20231619275 CPM-L-000207-23 05/23/2023 5:33:59 PM Pg 8 of 14 Trans ID: LCV20231619275 CPM-L-000207-23 05/23/2023 5:33:59 PM Pg 9 of 14 Trans ID: LCV20231619275 EXHIBIT B CPM-L-000207-23 05/23/2023 5:33:59 PM Pg 10 of 14 Trans ID: LCV20231619275 Midtown Building 1301 Atlantic Avenue Suite 400 Atlantic City, NJ 08401-7212 Tel (609) 348-4515 Fax (609) 348-6834 www.foxrothschild.com ADAM BUSLER Direct No: 609.572.2238 Email: ABusler@FoxRothschild.com April 28, 2023 VIA EMAIL Francis J. Ballak, Esquire Goldenberg, Mackler, Sayegh, Mintz , Pfeffer, Bonchi and Gill 660 New Road, First Floor Northfield, NJ 08225 Re: Service Rental Agreement between JT Laundry CM LLC d/b/a The Laundry Dude and the Desert Sand Resort (“CUSTOMER”) Dear Mr. Ballak: My firm represents JT Laundry CM LLC d/b/a the Laundry Dude (“Laundry Dude”). I write to demand arbitration pursuant to § 12 of the Service Rental Agreement (the “Contract”), dated April 6, 2022. A copy of the Contract is enclosed for your convenience. Pursuant to the Contract, Laundry Dude agreed “to furnish, clean, and pick up and deliver” various linens, including, but not limited to bed sheets, pillow cases, towels, and bath mats to the CUSTOMER. By executing the Contract, CUSTOMER agreed that Laundry Dude is the sole servicer of the items it provides to the CUSTOMER and that CUSTOMER was prohibited from using any linen service provider without Laundry Dude’s express written consent during the term of the Contract. As you may recall, § 9 of the Contract provides: Because it would be otherwise difficult or impractical to fix the exact amount of damage to [Laundry Dude], in the event the CUSTOMER cancels this [Contract] for any reason . . ., CUSTOMER will pay to LD 50% of the average weekly dollar volume for the unexpired term of the [C]ontract based off the 144785280.1 CPM-L-000207-23 05/23/2023 5:33:59 PM Pg 11 of 14 Trans ID: LCV20231619275 April 28, 2023 Page 2 average weekly business that is generated between the [CUSTOMER] and [Laundry Dude] leading up to the cancellation. Pursuant to § 11, the Contract was for a 36-month term commencing on April 12, 2022, the date of the first delivery. As such, the term of the Contract did not expire until April 11, 2025. Our records indicate that the CUSTOMER unilaterally terminated the Contract on April 29, 2022. As such, there were 141 weeks remaining on the Contract. Based on the CUSTOMER’s early termination of the Contract, a total of $44,007.51 remains due and owing to the Laundry Dude. This number is based on 50% of the average weekly dollar volume of the Contract ($627.22) times the unexpired term of the contract (141 weeks). CUSTOMER failed to respond to our letter dated September 8, 2022 demanding payment in connection with the CUSTOMER’s early termination of the Contract. Therefore, pursuant to § 12 of the Contract, the Laundry Dude hereby demands arbitration with a local arbitrator under the Federal Arbitration Act. We propose the following arbitrators: Honorable Michael A. Donio, J.S.C. (ret.), Honorable Francis J. Orlando, Jr., U.S.J. (ret.), or Honorable James E. Isman, J.S.C. (ret.). Should CUSTOMER fail to respond to this correspondence within ten (10) days, The Laundry Dude will file a summary action with the Court to compel arbitration. Please note that The Laundry Dude submits this letter without waiving any position, right, claim, remedy or defense – all of which are expressly reserved. Very truly yours, Adam Busler 144785280.1 CPM-L-000207-23 05/23/2023 5:33:59 PM Pg 12 of 14 Trans ID: LCV20231619275 CPM-L-000207-23 05/23/2023 5:33:59 PM Pg 13 of 14 Trans ID: LCV20231619275 CPM-L-000207-23 05/23/2023 5:33:59 PM Pg 14 of 14 Trans ID: LCV20231619275 CPM-L-000207-23 05/23/2023 CPM-L-000207-23 05/23/20235:33:59 5:33:59PM PM Pg 1 of 1 Trans TransID: ID:LCV20231619275 LCV20231619275 Civil Case Information Statement Case Details: CAPE MAY | Civil Part Docket# L-000207-23 Case Caption: JT LAUNDRY CM LLC VS DESERT SAND Case Type: SUMMARY ACTION RESORT Document Type: Complaint Case Initiation Date: 05/23/2023 Jury Demand: NONE Attorney Name: ADAM BUSLER Is this a professional malpractice case? NO Firm Name: FOX ROTHSCHILD LLP Related cases pending: NO Address: 1301 ATLANTIC AVE SUITE 400 If yes, list docket numbers: ATLANTIC CITY NJ 084017212 Do you anticipate adding any parties (arising out of same Phone: 6093484515 transaction or occurrence)? NO Name of Party: PLAINTIFF : JT Laundry CM LLC Does this case involve claims related to COVID-19? NO Name of Defendant’s Primary Insurance Company (if known): Unknown Are sexual abuse claims alleged by: JT Laundry CM LLC? NO THE INFORMATION PROVIDED ON THIS FORM CANNOT BE INTRODUCED INTO EVIDENCE CASE CHARACTERISTICS FOR PURPOSES OF DETERMINING IF CASE IS APPROPRIATE FOR MEDIATION Do parties have a current, past, or recurrent relationship? NO If yes, is that relationship: Does the statute governing this case provide for payment of fees by the losing party? NO Use this space to alert the court to any special case characteristics that may warrant individual management or accelerated disposition: Do you or your client need any disability accommodations? NO If yes, please identify the requested accommodation: Will an interpreter be needed? NO If yes, for what language: Please check off each applicable category: Putative Class Action? NO Title 59? NO Consumer Fraud? NO I certify that confidential personal identifiers have been redacted from documents now submitted to the court, and will be redacted from all documents submitted in the future in accordance with Rule 1:38-7(b) 05/23/2023 /s/ ADAM BUSLER Dated Signed