Complaint,Petition: Green Note Capital Partners Spv Llc v. Three C Exploration, Llc D/B/A THREE C EXPLORATION, Three C Oil & Gas, Llc THREE C OIL & GAS, Mohican Oil & Gas, Llc D/B/A MOHICAN OIL & GAS, Three C Exploration, Llc D/B/A THREE C EXPLORATION, Travis R Sharp

On September 05, 2023 a Complaint,Petition was filed involving a dispute between Green Note Capital Partners Spv Llc, and Mohican Oil & Gas, Llc D B A Mohican Oil & Gas, Three C Exploration, Llc D B A Three C Exploration, Three C Oil & Gas, Llc Three C Oil & Gas, Travis R Sharp, for Other Matters - Contract - Other in the District Court of Nassau County.

Preview
FILED: NASSAU COUNTY CLERK 09/05/2023 03:04 PM INDEX NO. 614331/2023
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/05/2023

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
GREEN NOTE CAPITAL PARTNERS SPV LLC Index No.:

Plaintiff Date Purchased

-against- SUMMONS

THREE C EXPLORATION, LLC D/B/A THREE C Plaintiff address is
EXPLORATION ; THREE C OIL & GAS, LLC D/B/A 1019 Ave P Suite 401
THREE C OIL & GAS; MOHICAN OIL & GAS, LLC Brooklyn, NY11223
D/B/A MOHICAN OIL & GAS; THREE C
EXPLORATION, LLC D/B/A THREE C
EXPLORATION
and
TRAVIS R SHARP

Defendants

TO THE ABOVE-NAMED DEFENDANTS:

YOU ARE HEREBY SUMMONED and required to serve upon Plaintiff attorney, at the
address stated below, an answer to the attached complaint. If this summons was personally delivered
upon you in the State of New York, the answer must be served within twenty days after such service
of the summons, excluding the date of service. If the summons was not personally delivered to you
within the State of New York, the answer must be served within thirty days after service of the
summons is complete as provided by law.
If you do not serve an answer to the attached complaint within the applicable time limitation
stated above, a judgment may be entered against you, by default, for the relief demanded in the
complaint, without further notice to you.
The basis for venue is pursuant to the Contract entered into between the parties.

Dated: Pomona, New York
September 5, 2023
/s/ariel bouskila
Ariel Bouskila, Esq.
Berkovitch & Bouskila, PLLC
Attorneys for Plaintiff
1545 U.S. 202, Suite 101
Pomona, New York 10970
Phone: (212)729-1477
Fax: (347)342-3192

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Defendants to be served:
THREE C EXPLORATION, LLC D/B/A
THREE C EXPLORATION; THREE C OIL &
GAS, LLC D/B/A THREE C OIL & GAS;
MOHICAN OIL & GAS, LLC D/B/A
MOHICAN OIL & GAS; THREE C
EXPLORATION, LLC D/B/A THREE C
EXPLORATION

1310 NORTH RIGMA
HEBBRONVILLE, TX 78361

TRAVIS R SHARP
1310 NORTH RIGMA
HEBBRONVILLE, TX 78361

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
GREEN NOTE CAPITAL PARTNERS SPV LLC Index No.:

Plaintiff,

-against- VERIFIED
COMPLAINT

THREE C EXPLORATION, LLC D/B/A THREE C
EXPLORATION ; THREE C OIL & GAS, LLC D/B/A THREE C
OIL & GAS; MOHICAN OIL & GAS, LLC D/B/A MOHICAN OIL
& GAS; THREE C EXPLORATION, LLC D/B/A THREE C
EXPLORATION and
TRAVIS R SHARP

Defendants

Plaintiff GREEN NOTE CAPITAL PARTNERS SPV LLC ("Plaintiff'), by its attorney,

Ariel Bouskila Esq., for its complaint herein against THREE C EXPLORATION, LLC D/B/A

THREE C EXPLORATION ; THREE C OIL & GAS, LLC D/B/A THREE C OIL & GAS;

MOHICAN OIL & GAS, LLC D/B/A MOHICAN OIL & GAS; THREE C EXPLORATION, LLC

D/B/A THREE C EXPLORATION (referred to collectively as "Company Defendant") and TRAVIS

R SHARP ("Guarantor") (Company Defendant and Guarantor, collectively "Defendants"), alleges

as follows:

The Parties

1. At all relevant times, Plaintiff was and is an entity authorized to do business in the State of

New York, with offices in the State of New York.

2. Upon information and belief, at all relevant times, Company Defendant was and is a

company organized and existing under the laws of the State of TX.

3. Upon information and belief, at all relevant times, Guarantor were and are individuals

residing in the State of TX.

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4. Venue is proper in Nassau pursuant to the Agreement entered into by and between the

parties.

5. This Court maintains personal jurisdiction over the Defendants in this Action pursuant to the

Agreement entered into by and between the parties.

The Facts

6. On or about February 09, 2023, Plaintiff and Defendants entered into an agreement (the

"Agreement") whereby Plaintiff agreed to purchase all rights to Company Defendant's future

receivables, having an agreed upon value of $44,970.00. A copy of the Agreement is

annexed hereto as Exhibit A.

7. Pursuant to the Agreement, Company Defendant agreed to remit to Plaintiff 14% (“Specified

Percentage”) of their receivables until the full purchased amount was remitted. Company

Defendant further agreed to have one bank account approved by Plaintiff (the "Bank

Account"), from which Company Defendant authorized Plaintiff to make ACH withdrawals

of the specified percentage of receivables until $44,970.00 (“Purchased Amount”) was fully

paid to Plaintiff. Said withdrawals were a good faith estimate of the Specified Percentage of

the Company Defendants’ receivables at the time the Agreement was entered into.

8. In addition, Guarantor agreed to guarantee any and all amounts owed to Plaintiff from

Company Defendant upon a breach in performance by Company Defendant.

9. Plaintiff remitted the Purchase Price for the future receivables to Company Defendant as

agreed. Initially, Company Defendant met its obligations under the Agreement.

10. Company Defendant ceased remitting to Plaintiff the Plaintiff’s share of Purchased

Receivables and otherwise breached the Agreement by intentionally impeding and

preventing Plaintiff from receiving the Specified Percentage of Company Defendants’

receivables, while conducting regular business operations and collecting revenue.

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11. Company Defendant remitted $32,980.00 of the receivables purchased by Plaintiff, leaving

a balance of unremitted receivables in the amount of $11,990.00. In addition, pursuant to the

Agreement, Company Defendant incurred other Default Fees in the amount of $2,500.00.

12. Despite due demand, Company Defendant has failed to remit the purchased amount due and

owing by Company Defendant to Plaintiff under the Agreement.

13. Additionally, Guarantor were responsible for all amounts incurred as a result of any breach

of the Company Defendant.

14. There remains a balance due and owing to Plaintiff on the Agreement in the amount of

$14,490.00 plus interest, costs, and disbursements.

AS AND FOR THE FIRST CAUSE OF ACTION
(Breach of Contract)
15. Plaintiff repeats and realleges each and every allegation contained in paragraphs 1 through

14 of this complaint as though fully set forth at length herein.

16. Plaintiff gave fair consideration to Company Defendant which was tendered for the right to

receive the aforementioned receivables. Accordingly, Plaintiff fully performed under the

Agreement.

17. Upon information and belief, Company Defendant is still conducting regular business

operations and still collecting receivables.

18. Company Defendant has materially breached the Agreement by failing to remit to Plaintiff

the Plaintiff’s share of Future Receivables, as required under the Agreement and otherwise

intentionally impeding and preventing Plaintiff from receiving the proceeds of the

receivables purchased by them.

19. By reason of the foregoing, Plaintiff has suffered damages in the amount of $14,490.00, plus

interest, costs, and disbursements.

AS AND FOR A SECOND CAUSE OF ACTION

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(Personal Guarantee)

20. Plaintiff repeats and realleges each and every allegation contained in paragraphs 1 through

19 of this complaint as though fully set forth at length herein.

21. Pursuant to the Agreement, Guarantor personally guaranteed that Company Defendant

would perform its obligations thereunder and that he or she would be personally liable for

any loss suffered by Plaintiff as a result of a breach by Company Defendant.

22. Company Defendant has breached the Agreement as detailed above.

23. By reason of the foregoing, Plaintiff is entitled to judgment against Guarantor based on his

or her personal guarantee in the sum of $14,490.00, plus interest, costs, and disbursements.

[THIS SPACE WAS LEFT BLANK INTENTIONALLY]

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WHEREFORE, plaintiff GREEN NOTE CAPITAL PARTNERS SPV LLC requests

judgment against defendants THREE C EXPLORATION, LLC D/B/A THREE C

EXPLORATION; THREE C OIL & GAS, LLC D/B/A THREE C OIL & GAS; MOHICAN

OIL & GAS, LLC D/B/A MOHICAN OIL & GAS; THREE C EXPLORATION, LLC D/B/A

THREE C EXPLORATION and TRAVIS R SHARP as follows:

i) On the first cause of action of the complaint, Plaintiff requests judgment against

Company Defendant in the amount of $14,490.00, plus interest, costs, and

disbursements;

ii) On the second cause of action of the complaint, Plaintiffs request judgment

against Guarantor in the amount of $14,490.00, plus interest, costs, and

disbursements;

iii) For such other and further relief as this Court deems just and proper.

Dated: Pomona, New York
September 5, 2023
/s/ariel bouskila
Ariel Bouskila, Esq.
Berkovitch & Bouskila, PLLC
Attorneys for Plaintiff
Pomona, New York 10970
Phone:(212)729-1477
Fax:(347)342-3192

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
GREEN NOTE CAPITAL PARTNERS SPV LLC Index No.:

Plaintiff,

-against-

Defendant(s)

NOTICE OF COMMENCEMENT OF ACTION
SUBJECT TO MANDATORY ELECTRONIC FILING

PLEASE TAKE NOTICE that the matter captioned above, which has been commenced by
filing of the accompanying documents with the County Clerk, is subject to mandatory electronic
filing pursuant to Section 202.5-bb of the Uniform Rules for the Trial Courts. This notice is being
served as required by Subdivision (b)(3) of that Section.
The New York State Courts Electronic Filing System ("NYSCEF") is designed for the
electronic filing of documents with the County Clerk and the court and for the electronic service of
those documents, court documents, and court notices upon counsel and self-represented parties.
Counsel and/or parties who do not notify the court of a claimed exemption (see below) as required
by Section 202.5-bb(e) must immediately record their representation within the e-filed matter on the
Consent page in NYSCEF. Failure to do so may result in an inability to receive electronic notice of
document filings.
Exemptions from mandatory e-filing are limited to: 1) attorneys who certify in good faith
that they lack the computer equipment and (along with all employees) the requisite knowledge to
comply; and 2) self-represented parties who choose not to participate in e-filing. For additional
information about electronic filing, including access to Section 202.5-bb, consult the NYSCEF
website at www.nycourts.gov/efile or contact the NYSCEF Resource Center at 646-386-3033 or
efile@courts.state.ny.us.

Dated: September 5, 2023
/s/ariel bouskila
Ariel Bouskila, Esq.
Berkovitch & Bouskila, PLLC
Attorneys for Plaintiff
1545 U.S. 202, Suite 101
Pomona, New York 10970
Phone:(212)729-1477
Fax:(347)342-3192

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STATE OF NEW YORK )

COUNTY OF NEW YORK ) ss.:

GABRIEL MANN, being duly sworn, states:

I am an authorized representative of Plaintiff GREEN NOTE CAPITAL PARTNERS SPV

LLC in the within action. I have read the foregoing Verified Complaint and know the contents thereof;

the same is true to my knowledge, except as to the matters therein stated to be alleged upon information

and belief, and as to those matters, I believe them to be true.

The foregoing statements are true under penalties of perjury.

By:
GABRIEL MANN,

Sworn to before me this

September 5, 2023.

___________________________

Notary Public

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Case Info

Case No.

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Document Filed Date

September 05, 2023

Case Filing Date

September 05, 2023

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