On August 20, 2023 a
Exhibit,Appendix
was filed
involving a dispute between
Joana R. Moreno,
Photios M. Giannakos,
Richard B. Mith,
and
Ginna Borrello,
Richard Borrello,
Seamless Auto Llc,
for Torts - Other (unpaid wages)
in the District Court of Bronx County.
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FILED: BRONX COUNTY CLERK 08/20/2023 12:10 PM INDEX NO. 812789/2023E
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 08/20/2023
NOTICE OF INTENTION TO ENFORCE MEMBER LIABILITY FOR SERVICES
RENDERED
TO: GINNA BORRELLO and RICHARD BORRELLO
PLEASE TAKE NOTICE that, pursuant to the provisions of Section 609(c) of the
Limited Liability Company Law of the State of New York, you are hereby notified that PHOTIOS
M. GIANNAKOS, RICHARD B. MITH, and JOANA R. MORENO intend to charge you and hold
you personally liable, jointly and severally, as among the ten members with the largest percentage
ownership interest in SEAMLESS AUTO LLC, for all debts, wages, and/or salaries due and owing
to them as laborers, servants, and/or employees of the said entity for services performed by them
for the said entity within the 6 years preceding the date of this notice and have expressly authorized
the undersigned, as their attorneys, to make this demand on their behalf.
Dated: Flushing, NY
August 20, 2023
TROY LAW, PLLC
Attorneys for Plaintiffs
/s/ John Troy
John Troy, Esq.
41-25 Kissena Boulevard
Suite 110
Flushing, NY 11355
(718) 762-1324
troylaw@troypllc.com
Document Filed Date
August 20, 2023
Case Filing Date
August 20, 2023
Category
Torts - Other (unpaid wages)
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FILED: BRONX COUNTY CLERK 08/20/2023 12:10 PM INDEX NO. 812789/2023E NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 08/20/2023 NOTICE OF INTENTION TO ENFORCE MEMBER LIABILITY FOR SERVICES RENDERED TO: GINNA BORRELLO and RICHARD BORRELLO PLEASE TAKE NOTICE that, pursuant to the provisions of Section 609(c) of the Limited Liability Company Law of the State of New York, you are hereby notified that PHOTIOS M. GIANNAKOS, RICHARD B. MITH, and JOANA R. MORENO intend to charge you and hold you personally liable, jointly and severally, as among the ten members with the largest percentage ownership interest in SEAMLESS AUTO LLC, for all debts, wages, and/or salaries due and owing to them as laborers, servants, and/or employees of the said entity for services performed by them for the said entity within the 6 years preceding the date of this notice and have expressly authorized the undersigned, as their attorneys, to make this demand on their behalf. Dated: Flushing, NY August 20, 2023 TROY LAW, PLLC Attorneys for Plaintiffs /s/ John Troy John Troy, Esq. 41-25 Kissena Boulevard Suite 110 Flushing, NY 11355 (718) 762-1324 troylaw@troypllc.com