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  • Richard J. Digeronimo, R.D. Geronimo, Ltd v. Property Analytix, Llc, Archstone Group Nyc Llc, Michael Miller, Royce Ashton Rowles, Ryan Lin Commercial Division - Contract document preview
  • Richard J. Digeronimo, R.D. Geronimo, Ltd v. Property Analytix, Llc, Archstone Group Nyc Llc, Michael Miller, Royce Ashton Rowles, Ryan Lin Commercial Division - Contract document preview
						
                                

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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