On January 05, 2022 a
Exhibit,Appendix
was filed
involving a dispute between
R.D. Geronimo, Ltd,
Richard J. Digeronimo,
and
Archstone Group Nyc Llc,
Michael Miller,
Property Analytix, Llc,
Royce Ashton Rowles,
Ryan Lin,
for Commercial Division - Contract
in the District Court of Nassau County.
Preview
FILED: NASSAU COUNTY CLERK 08/28/2023 05:49 PM INDEX NO. 608383/2023
NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 08/28/2023
SUPREME COURT OF THE STATE OF NEW YORK UCS-840C
3/2011
COUNTY OF Nassau
x Index No: 608383/2023
Richard J. DiGeronimo, R.D. Geronimo, LTD RJI No. (if any):
Plaintiff(s)/Petitioner(s)
-against-
COMMERCIAL DIVISION
Property Analytix, LLC, Archstone Group NYC LLC, Michael Miller,
Royce Ashton Rowles, Ryan Lin Request for Judicial Intervention Addendum
Defendant(s)/Respondent(s)
x
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)
☐ Transactions governed by the Uniform Commercial Code (exclusive of those concerning individual cooperative or condominium
units)
☐ Transactions involving commercial real property, including Yellowstone injunctions and excluding actions for the payment of rent
only
☐ Shareholder derivative actions — without consideration of the monetary threshold
☐ Commercial class actions — without consideration of the monetary threshold
☐ Business transactions involving or arising out of dealings with commercial banks and other financial institutions
☐ Internal affairs of business organizations
☐ Malpractice by accountants or actuaries, and legal malpractice arising out of representation in commercial matters
☐ Environmental insurance coverage
☐ Commercial insurance coverage (e.g. directors and officers, errors and omissions, and business interruption coverage)
☐ Dissolution of corporations, partnerships, limited liability companies, limited liability partnerships and joint ventures — without
consideration of the monetary threshold
☐ 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]:
700000.00
Plaintiff/Petitioner’s claim for equitable or declaratory relief [brief description]:
Termination of Non-Competition Agreement, Unenforceability of Clawback Provision
Defendant/Respondent’s counterclaim(s) [brief description, including claim for monetary relief]:
Breach of Contract, Breach of Covenant of Good Faith and Fair Dealing, Breach of Fiduciary Duty, Faithless Servant Doctrine,
Declaratory Judgment that Defendants' Obligations under APA, Promissory Note, and Guaranty are Terminated, Damages of $1.7
million
I REQUEST THAT THIS CASE BE ASSIGNED TO THE COMMERCIAL DIVISION. I CERTIFY THAT THE CASE MEETS THE
JURISDICTIONAL REQUIREMENTS OF THE COMMERCIAL DIVISION SET FORTH IN 22 NYCRR § 202.70(a), (b) and (c).
Dated: 08/28/2023 KENNETH J KATZ
SIGNATURE
KENNETH J KATZ
This form was generated by NYSCEF PRINT OR TYPE NAME
1 of 1
Document Filed Date
August 28, 2023
Case Filing Date
January 05, 2022
Category
Commercial Division - Contract
For full print and download access, please subscribe at https://www.trellis.law/.