Preview
FILED: KINGS COUNTY CLERK 09/19/2023 04:34 PM INDEX NO. 527195/2023
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
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MAYFAIR BUSINESS CAPITAL LLC, Index No.:
Date Filed:
PLAINTIFF,
SUMMONS
-AGAINST- Plaintiff's Place of Business:
7 Henry Court
US21 INTERNATIONAL INC, SOONI & TOMMI LLC, J & J Suffern, NY 10901
FAMILY USA LLC, US21 GEORGIA LLC, J AND J FAMILY
USA, LLC, US21 I'TIONAL LLC, SOONI AND TOMMI LLC, The basis of the venue is pursuant
MJ ILLINOIS LLC, INTERNATIONAL MISSION JESUS to the contract entered into
INC, and JUNGHOON KIM, between the parties. Plaintiff
designates KINGS County as the
DEFENDANT(S), place of trial.
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TO THE ABOVE-NAMED DEFENDANT(S):
YOU ARE HEREBY SUMMONED to answer the Complaint in this action and to serve a copy
of your Answer, or, if the complaint is not served with the summons, to serve a notice of appearance, on
the Plaintiff’s attorney within twenty (20) days after the service of this Summons, exclusive of the day
of service (or within thirty (30) days after completion of service where service is not personally
delivered to you within the State of New York); and, in case of your failure to Appear or Answer,
judgment will be taken against you by default for the relief demanded in the Complaint.
Dated: Suffern, New York
September 19, 2023
______
Isaac H. Greenfield, Esq.
Law Offices of Isaac H. Greenfield, PLLC
Attorney for Plaintiff
2 Executive Blvd., Ste. 305
Suffern, NY 10901
Phone: (718) 564-6268
Fax: (516) 387-1117
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Defendants to be served:
US21 INTERNATIONAL INC;
SOONI & TOMMI LLC;
J & J FAMILY USA LLC
5000 Heatherwood Ct, Roswell, GA 30075
US21 GEORGIA LLC
5200 Medlock Bridge Rd Ste 140, Peachtree Corners, GA 30092
J AND J FAMILY USA, LLC;
US21 I'TIONAL LLC;
SOONI AND TOMMI LLC
10820 Abbotts Bridge Rd Ste 330, Johns Creek, GA 30097
MJ ILLINOIS LLC
411 Hamilton Blvd Ste 1927, Peoria, IL 61602
INTERNATIONAL MISSION JESUS INC
1712 Broad St, Selma, AL 36701
JUNGHOON KIM
5000 Heatherwood Ct, Roswell, GA 30075
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FILED: KINGS COUNTY CLERK 09/19/2023 04:34 PM INDEX NO. 527195/2023
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
------------------------------------------------------------------------------X
MAYFAIR BUSINESS CAPITAL LLC,
INDEX NO.:
DATE FILED:
PLAINTIFF,
-AGAINST- VERIFIED COMPLAINT
US21 INTERNATIONAL INC, SOONI & TOMMI LLC, J & J
FAMILY USA LLC, US21 GEORGIA LLC, J AND J FAMILY
USA, LLC, US21 I'TIONAL LLC, SOONI AND TOMMI LLC,
MJ ILLINOIS LLC, INTERNATIONAL MISSION JESUS
INC, and JUNGHOON KIM,
DEFENDANT(S).
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Plaintiff, MAYFAIR BUSINESS CAPITAL LLC, by its attorney, Isaac H. Greenfield, Esq, complaining of
the defendant(s), respectfully alleges:
1. Plaintiff, MAYFAIR BUSINESS CAPITAL LLC, is an entity organized under the laws of the United States
of America. Plaintiff is an entity authorized to do business in the State of New York.
2. Upon information and belief, at all relevant times Company Defendants US21 INTERNATIONAL INC,
SOONI & TOMMI LLC, J & J FAMILY USA LLC, US21 GEORGIA LLC, J AND J FAMILY USA, LLC,
US21 I'TIONAL LLC, SOONI AND TOMMI LLC, MJ ILLINOIS LLC, and INTERNATIONAL MISSION
JESUS INC (collectively, hereinafter “Company Defendant”) were and are companies organized and existing
under the laws of Georgia, Illinois, and Alabama, respectively.
3. Upon information and belief, at all relevant times, Defendant Guarantor JUNGHOON KIM (hereinafter
“Defendant Guarantor”) was and is an individual residing in the State of Georgia. “Defendants” shall include
Company Defendant and Defendant Guarantor.
VENUE
4. Venue is proper in this breach of contract claim, pursuant to the subject contract which contains a clause
specifying that New York is the exclusive jurisdiction for all disputes arising under the contract.
THE FACTS
5. On or about September 07, 2023, Plaintiff and Company Defendant entered into a Standard Merchant Cash
Advance Agreement (hereinafter the “Agreement”) whereby Plaintiff agreed to purchase all rights of Company
Defendant’s future receivables having an agreed upon value of $22,485.00. The purchase price for said
receivables was $15,000.00.
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2023
6. In addition, Defendant Guarantor personally guaranteed any and all amounts owed to Plaintiff from Company
Defendant, upon a breach in performance by Company Defendant.
7. Pursuant to the Agreement, Company Defendant agreed to have one bank account approved by Plaintiff from
which Company Defendant authorized Plaintiff to make daily ACH withdrawals until the $22,485.00 was fully
paid to Plaintiff.
8. Plaintiff remitted the purchase price for the future receivables to Company Defendant as agreed.
9. Initially, Company Defendant met its obligation under the Agreement, however, on or about September 12,
2023, Company Defendant breached the Agreement by failing to perform its obligations under the terms of the
Agreement, by blocking and depriving Plaintiff of its daily ACH withdrawals from the specified bank account
all while still conducting regular business operations. Company Defendant has paid a total of $3,000.00 to
Plaintiff leaving a balance due and owing the amount of $19,485.00.
10. In addition, pursuant to Section 2(C) of the Agreement, Company Defendant incurred a Default Fee in the
amount of $6,430.05 (which, upon the occurrence of an event of default, is calculated as thirty-three percent
(33%) of the remaining balance of the purchased amount of future receivables to be applied to the balance owed
to Plaintiff) for Company Defendant’s failure to direct the agreed upon payment(s) to Plaintiff and for Company
Defendant changing its bank account from the specified bank account.
11. Despite due demand, Company Defendant has failed to pay the amounts due and owing by Company Defendant
to Plaintiff under the Agreement.
12. Additionally, Defendant Guarantor are responsible for all amounts incurred as a result of any default of the
Company Defendant.
13. There remains a balance due and owing to Plaintiff on the Agreement in the amount of $25,915.05 plus interest
from September 12, 2023, costs, disbursements and attorney’s fees.
FOR A FIRST CAUSE OF ACTION: BREACH OF CONTRACT
14. Plaintiff repeats and re-alleges each and every allegation contained in paragraphs 1 through 13 of this complaint
as though fully set forth at length herein.
15. 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.
16. Upon information and belief, Company Defendant is still conducting regular business operations and still
collecting receivables.
17. Company Defendant has materially breached the Agreement by failing to divert the specified payment amount
to Plaintiff as required under the Agreement.
18. Upon information and belief, Company Defendant has also materially breached the Agreement by using more
than one depositing bank account which has not been approved by Plaintiff.
19. By reason of the foregoing, Plaintiff has suffered damages and is entitled to judgment against Company
Defendant based on Company Defendant’s breach of contract in the amount of $25,915.05, plus interest from
September 12, 2023, costs, disbursements and attorney’s fees.
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2023
FOR A SECOND CAUSE OF ACTION: PERSONAL GUARANTEE
20. Plaintiff repeats and re-alleges each and every allegation contained in paragraph 1 through 19 of this complaint
as though fully set forth at length herein.
21. Pursuant to the Agreement, Defendant 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 certain breaches by Company Defendant.
22. Company Defendant has breached the Agreement by failing to pay its obligations to Plaintiff.
23. By reason of the foregoing, Plaintiff is entitled to judgment against Defendant Guarantor based on his or her
personal guarantee in the sum of $25,915.05, plus interest from September 12, 2023, costs, disbursements and
attorney’s fees.
WHEREFORE, Plaintiff MAYFAIR BUSINESS CAPITAL LLC requests judgment against Defendants US21
INTERNATIONAL INC, SOONI & TOMMI LLC, J & J FAMILY USA LLC, US21 GEORGIA LLC, J AND J
FAMILY USA, LLC, US21 I'TIONAL LLC, SOONI AND TOMMI LLC,
MJ ILLINOIS LLC, INTERNATIONAL MISSION JESUS INC, and JUNGHOON KIM as follows:
(a) on the first cause of action of the complaint, Plaintiff, MAYFAIR BUSINESS CAPITAL LLC requests
judgment against Company Defendant in the sum of $25,915.05, plus interest from September 12, 2023,
costs and attorney's fees;
(b) on the second cause of action of the complaint, Plaintiff MAYFAIR BUSINESS CAPITAL LLC requests
judgment against Defendant Guarantor in the amount of $25,915.05, plus interest from September 12, 2023,
costs and attorney's fees;
(c) for such other further relief as this Court deems just and proper.
Dated: Suffern, New York
September 19, 2023
__
Isaac H. Greenfield, Esq.
Law Offices of Isaac H. Greenfield PLLC
Attorney for Plaintiff
2 Executive Blvd., Ste. 305
Suffern, NY 10901
Phone: (718) 564-6268
Fax: (516) 387-1117
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2023
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FILED: KINGS COUNTY CLERK 09/19/2023 04:34 PM INDEX NO. 527195/2023
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
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MAYFAIR BUSINESS CAPITAL LLC,
INDEX NO.:
PLAINTIFF,
-AGAINST-
US21 INTERNATIONAL INC, SOONI & TOMMI LLC, J & J
FAMILY USA LLC, US21 GEORGIA LLC, J AND J FAMILY
USA, LLC, US21 I'TIONAL LLC, SOONI AND TOMMI LLC,
MJ ILLINOIS LLC, INTERNATIONAL MISSION JESUS
INC, and JUNGHOON KIM,
DEFENDANT(S).
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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: Suffern, New York
September 19, 2023
__ ___
Isaac H. Greenfield, Esq.
Law Offices of Isaac H. Greenfield, PLLC
Attorney for Plaintiff
2 Executive Blvd., Ste. 305
Suffern, NY 10901
Phone: (718) 564-6268
Fax: (516) 387-1117
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Preview
FILED: KINGS COUNTY CLERK 09/19/2023 04:34 PM INDEX NO. 527195/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ----------------------------------------------------------------------------X MAYFAIR BUSINESS CAPITAL LLC, Index No.: Date Filed: PLAINTIFF, SUMMONS -AGAINST- Plaintiff's Place of Business: 7 Henry Court US21 INTERNATIONAL INC, SOONI & TOMMI LLC, J & J Suffern, NY 10901 FAMILY USA LLC, US21 GEORGIA LLC, J AND J FAMILY USA, LLC, US21 I'TIONAL LLC, SOONI AND TOMMI LLC, The basis of the venue is pursuant MJ ILLINOIS LLC, INTERNATIONAL MISSION JESUS to the contract entered into INC, and JUNGHOON KIM, between the parties. Plaintiff designates KINGS County as the DEFENDANT(S), place of trial. ---------------------------------------------------------------------------X TO THE ABOVE-NAMED DEFENDANT(S): YOU ARE HEREBY SUMMONED to answer the Complaint in this action and to serve a copy of your Answer, or, if the complaint is not served with the summons, to serve a notice of appearance, on the Plaintiff’s attorney within twenty (20) days after the service of this Summons, exclusive of the day of service (or within thirty (30) days after completion of service where service is not personally delivered to you within the State of New York); and, in case of your failure to Appear or Answer, judgment will be taken against you by default for the relief demanded in the Complaint. Dated: Suffern, New York September 19, 2023 ______ Isaac H. Greenfield, Esq. Law Offices of Isaac H. Greenfield, PLLC Attorney for Plaintiff 2 Executive Blvd., Ste. 305 Suffern, NY 10901 Phone: (718) 564-6268 Fax: (516) 387-1117 1 of 7 FILED: KINGS COUNTY CLERK 09/19/2023 04:34 PM INDEX NO. 527195/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2023 Defendants to be served: US21 INTERNATIONAL INC; SOONI & TOMMI LLC; J & J FAMILY USA LLC 5000 Heatherwood Ct, Roswell, GA 30075 US21 GEORGIA LLC 5200 Medlock Bridge Rd Ste 140, Peachtree Corners, GA 30092 J AND J FAMILY USA, LLC; US21 I'TIONAL LLC; SOONI AND TOMMI LLC 10820 Abbotts Bridge Rd Ste 330, Johns Creek, GA 30097 MJ ILLINOIS LLC 411 Hamilton Blvd Ste 1927, Peoria, IL 61602 INTERNATIONAL MISSION JESUS INC 1712 Broad St, Selma, AL 36701 JUNGHOON KIM 5000 Heatherwood Ct, Roswell, GA 30075 2 of 7 FILED: KINGS COUNTY CLERK 09/19/2023 04:34 PM INDEX NO. 527195/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ------------------------------------------------------------------------------X MAYFAIR BUSINESS CAPITAL LLC, INDEX NO.: DATE FILED: PLAINTIFF, -AGAINST- VERIFIED COMPLAINT US21 INTERNATIONAL INC, SOONI & TOMMI LLC, J & J FAMILY USA LLC, US21 GEORGIA LLC, J AND J FAMILY USA, LLC, US21 I'TIONAL LLC, SOONI AND TOMMI LLC, MJ ILLINOIS LLC, INTERNATIONAL MISSION JESUS INC, and JUNGHOON KIM, DEFENDANT(S). ------------------------------------------------------------------------------X Plaintiff, MAYFAIR BUSINESS CAPITAL LLC, by its attorney, Isaac H. Greenfield, Esq, complaining of the defendant(s), respectfully alleges: 1. Plaintiff, MAYFAIR BUSINESS CAPITAL LLC, is an entity organized under the laws of the United States of America. Plaintiff is an entity authorized to do business in the State of New York. 2. Upon information and belief, at all relevant times Company Defendants US21 INTERNATIONAL INC, SOONI & TOMMI LLC, J & J FAMILY USA LLC, US21 GEORGIA LLC, J AND J FAMILY USA, LLC, US21 I'TIONAL LLC, SOONI AND TOMMI LLC, MJ ILLINOIS LLC, and INTERNATIONAL MISSION JESUS INC (collectively, hereinafter “Company Defendant”) were and are companies organized and existing under the laws of Georgia, Illinois, and Alabama, respectively. 3. Upon information and belief, at all relevant times, Defendant Guarantor JUNGHOON KIM (hereinafter “Defendant Guarantor”) was and is an individual residing in the State of Georgia. “Defendants” shall include Company Defendant and Defendant Guarantor. VENUE 4. Venue is proper in this breach of contract claim, pursuant to the subject contract which contains a clause specifying that New York is the exclusive jurisdiction for all disputes arising under the contract. THE FACTS 5. On or about September 07, 2023, Plaintiff and Company Defendant entered into a Standard Merchant Cash Advance Agreement (hereinafter the “Agreement”) whereby Plaintiff agreed to purchase all rights of Company Defendant’s future receivables having an agreed upon value of $22,485.00. The purchase price for said receivables was $15,000.00. 3 of 7 FILED: KINGS COUNTY CLERK 09/19/2023 04:34 PM INDEX NO. 527195/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2023 6. In addition, Defendant Guarantor personally guaranteed any and all amounts owed to Plaintiff from Company Defendant, upon a breach in performance by Company Defendant. 7. Pursuant to the Agreement, Company Defendant agreed to have one bank account approved by Plaintiff from which Company Defendant authorized Plaintiff to make daily ACH withdrawals until the $22,485.00 was fully paid to Plaintiff. 8. Plaintiff remitted the purchase price for the future receivables to Company Defendant as agreed. 9. Initially, Company Defendant met its obligation under the Agreement, however, on or about September 12, 2023, Company Defendant breached the Agreement by failing to perform its obligations under the terms of the Agreement, by blocking and depriving Plaintiff of its daily ACH withdrawals from the specified bank account all while still conducting regular business operations. Company Defendant has paid a total of $3,000.00 to Plaintiff leaving a balance due and owing the amount of $19,485.00. 10. In addition, pursuant to Section 2(C) of the Agreement, Company Defendant incurred a Default Fee in the amount of $6,430.05 (which, upon the occurrence of an event of default, is calculated as thirty-three percent (33%) of the remaining balance of the purchased amount of future receivables to be applied to the balance owed to Plaintiff) for Company Defendant’s failure to direct the agreed upon payment(s) to Plaintiff and for Company Defendant changing its bank account from the specified bank account. 11. Despite due demand, Company Defendant has failed to pay the amounts due and owing by Company Defendant to Plaintiff under the Agreement. 12. Additionally, Defendant Guarantor are responsible for all amounts incurred as a result of any default of the Company Defendant. 13. There remains a balance due and owing to Plaintiff on the Agreement in the amount of $25,915.05 plus interest from September 12, 2023, costs, disbursements and attorney’s fees. FOR A FIRST CAUSE OF ACTION: BREACH OF CONTRACT 14. Plaintiff repeats and re-alleges each and every allegation contained in paragraphs 1 through 13 of this complaint as though fully set forth at length herein. 15. 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. 16. Upon information and belief, Company Defendant is still conducting regular business operations and still collecting receivables. 17. Company Defendant has materially breached the Agreement by failing to divert the specified payment amount to Plaintiff as required under the Agreement. 18. Upon information and belief, Company Defendant has also materially breached the Agreement by using more than one depositing bank account which has not been approved by Plaintiff. 19. By reason of the foregoing, Plaintiff has suffered damages and is entitled to judgment against Company Defendant based on Company Defendant’s breach of contract in the amount of $25,915.05, plus interest from September 12, 2023, costs, disbursements and attorney’s fees. 4 of 7 FILED: KINGS COUNTY CLERK 09/19/2023 04:34 PM INDEX NO. 527195/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2023 FOR A SECOND CAUSE OF ACTION: PERSONAL GUARANTEE 20. Plaintiff repeats and re-alleges each and every allegation contained in paragraph 1 through 19 of this complaint as though fully set forth at length herein. 21. Pursuant to the Agreement, Defendant 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 certain breaches by Company Defendant. 22. Company Defendant has breached the Agreement by failing to pay its obligations to Plaintiff. 23. By reason of the foregoing, Plaintiff is entitled to judgment against Defendant Guarantor based on his or her personal guarantee in the sum of $25,915.05, plus interest from September 12, 2023, costs, disbursements and attorney’s fees. WHEREFORE, Plaintiff MAYFAIR BUSINESS CAPITAL LLC requests judgment against Defendants US21 INTERNATIONAL INC, SOONI & TOMMI LLC, J & J FAMILY USA LLC, US21 GEORGIA LLC, J AND J FAMILY USA, LLC, US21 I'TIONAL LLC, SOONI AND TOMMI LLC, MJ ILLINOIS LLC, INTERNATIONAL MISSION JESUS INC, and JUNGHOON KIM as follows: (a) on the first cause of action of the complaint, Plaintiff, MAYFAIR BUSINESS CAPITAL LLC requests judgment against Company Defendant in the sum of $25,915.05, plus interest from September 12, 2023, costs and attorney's fees; (b) on the second cause of action of the complaint, Plaintiff MAYFAIR BUSINESS CAPITAL LLC requests judgment against Defendant Guarantor in the amount of $25,915.05, plus interest from September 12, 2023, costs and attorney's fees; (c) for such other further relief as this Court deems just and proper. Dated: Suffern, New York September 19, 2023 __ Isaac H. Greenfield, Esq. Law Offices of Isaac H. Greenfield PLLC Attorney for Plaintiff 2 Executive Blvd., Ste. 305 Suffern, NY 10901 Phone: (718) 564-6268 Fax: (516) 387-1117 5 of 7 FILED: KINGS COUNTY CLERK 09/19/2023 04:34 PM INDEX NO. 527195/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2023 6 of 7 FILED: KINGS COUNTY CLERK 09/19/2023 04:34 PM INDEX NO. 527195/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/19/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS --------------------------------------------------------------------------------X MAYFAIR BUSINESS CAPITAL LLC, INDEX NO.: PLAINTIFF, -AGAINST- US21 INTERNATIONAL INC, SOONI & TOMMI LLC, J & J FAMILY USA LLC, US21 GEORGIA LLC, J AND J FAMILY USA, LLC, US21 I'TIONAL LLC, SOONI AND TOMMI LLC, MJ ILLINOIS LLC, INTERNATIONAL MISSION JESUS INC, and JUNGHOON KIM, DEFENDANT(S). -----------------------------------------------------------------------------------X 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: Suffern, New York September 19, 2023 __ ___ Isaac H. Greenfield, Esq. Law Offices of Isaac H. Greenfield, PLLC Attorney for Plaintiff 2 Executive Blvd., Ste. 305 Suffern, NY 10901 Phone: (718) 564-6268 Fax: (516) 387-1117 7 of 7