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FILED: NASSAU COUNTY CLERK 09/23/2023 04:04 PM INDEX NO. 602826/2022
NYSCEF DOC. NO. 147 RECEIVED NYSCEF: 09/23/2023
Jonathan Marc Davidoff, Esq. Aaron R. Resnick, Esq.
Admitted in New York and Florida Admitted in Florida, of Counsel
Danielle Shayne Shapero, Esq. Derek A. Schwartz, Esq,
Admitted in New York Admitted in Florida, of Counsel
August 28, 2023
VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND EMAIL
ROSEN LAW, LLC
Attn.: Gary Rosen, Esq.
216 Lakeville Road
Great Neck, New York 11020
(516) 437-3400
Re: Subpoena Duces Tecum to Rosen Law LLC
Ben-Zion Alcalay v. Atlas Cybersecurity LLC, and Barry Dynkin
Nassau County Supreme Court Index No.: 602826/2022
Dear Mr. Rosen,
We write on behalf of our client, Ben-Zion Alcalay. On May 19, 2023, the Supreme Court
of the State of New York, County of Nassau, entered a judgement in favor of our client and against
Barry Dynkin (“Barry”) and Atlas Cybersecurity LLC (“Atlas”), for the sum of $293,291.40
together with interest in the sum of $39,137.05, for the total sum of $332,428.45, with post-
judgement interest accruing (the “Judgment”). The Judgment is still due and owing to Mr. Alcalay.
Further to the Judgement entered against Barry and Atlas, we understand that you received
payments from Barry and/or Atlas or from third parties on behalf of Barry and Atlas. On July 7,
2023, under the authority of In re Two Sams Associates, LLC, 2006 WL 8209668 (Sup. Ct. N.Y.
Cnty., June 12, 2006, Kornreich, J.), we served upon Rosen Law LLC a Restraining Notice, which
was effective immediately on said date, related to all such sums for the benefit of Barry and Atlas
and an Information Subpoena requesting that Rosen Law LLC furnish in writing and under oath
answers to the questions.
Further to the Judgement entered against Barry and Atlas we serve upon you the enclosed
Subpoena Duces Tecum for the production of documents requiring Rosen Law LLC to provide
documents required therein. Please be advised that Rosen Laws failure to comply is punishable by
contempt.
228 East 45th Street 100 North Biscayne Blvd
Suite 1110 Suite 1607
New York, NY 10017 Miami, FL 33132
Tel: (212) 587-5971 Tel: (305) 672-7495
Fax: (212) 658-9852 Fax: (305) 718-0647
www.DavidoffLawFirm.com
FILED: NASSAU COUNTY CLERK 09/23/2023 04:04 PM INDEX NO. 602826/2022
NYSCEF DOC. NO. 147 RECEIVED NYSCEF: 09/23/2023
Should Rosen Law LLC have any question regarding any of the disclosures, please contact
us at the information on the prior page. You may also contract the undersigned at 212-587-5971.
Very truly yours,
Jonathan Marc Davidoff, Esq.
Counsel for Plaintiff/Judgment Creditor Ben-Zion Alcalay
Enclosures:
• Subpoena Duces Tecum to Rosen Law, LLC
• Supreme Court of the State of New York, County of Nassau, Judgment against Barry
Dynkin and Atlas Cybersecurity, LLC, dated May 18, 2023
• Judgment of the Circuit Court of the 15th Judicial Circuit in and for Palm Beach County
Florida dated December 7, 2021
cc: Barry Dynkin and Atlas Cybersecurity, LLC
Page 2 of 2
DAVIDOFF LAW FIRM, PLLC
228 East 45th Street, Suite 1110, New York, NY 10017 ● Telephone (212) 587-5971 ● Fax (212) 658-9852
Preview
FILED: NASSAU COUNTY CLERK 09/23/2023 04:04 PM INDEX NO. 602826/2022 NYSCEF DOC. NO. 147 RECEIVED NYSCEF: 09/23/2023 Jonathan Marc Davidoff, Esq. Aaron R. Resnick, Esq. Admitted in New York and Florida Admitted in Florida, of Counsel Danielle Shayne Shapero, Esq. Derek A. Schwartz, Esq, Admitted in New York Admitted in Florida, of Counsel August 28, 2023 VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND EMAIL ROSEN LAW, LLC Attn.: Gary Rosen, Esq. 216 Lakeville Road Great Neck, New York 11020 (516) 437-3400 Re: Subpoena Duces Tecum to Rosen Law LLC Ben-Zion Alcalay v. Atlas Cybersecurity LLC, and Barry Dynkin Nassau County Supreme Court Index No.: 602826/2022 Dear Mr. Rosen, We write on behalf of our client, Ben-Zion Alcalay. On May 19, 2023, the Supreme Court of the State of New York, County of Nassau, entered a judgement in favor of our client and against Barry Dynkin (“Barry”) and Atlas Cybersecurity LLC (“Atlas”), for the sum of $293,291.40 together with interest in the sum of $39,137.05, for the total sum of $332,428.45, with post- judgement interest accruing (the “Judgment”). The Judgment is still due and owing to Mr. Alcalay. Further to the Judgement entered against Barry and Atlas, we understand that you received payments from Barry and/or Atlas or from third parties on behalf of Barry and Atlas. On July 7, 2023, under the authority of In re Two Sams Associates, LLC, 2006 WL 8209668 (Sup. Ct. N.Y. Cnty., June 12, 2006, Kornreich, J.), we served upon Rosen Law LLC a Restraining Notice, which was effective immediately on said date, related to all such sums for the benefit of Barry and Atlas and an Information Subpoena requesting that Rosen Law LLC furnish in writing and under oath answers to the questions. Further to the Judgement entered against Barry and Atlas we serve upon you the enclosed Subpoena Duces Tecum for the production of documents requiring Rosen Law LLC to provide documents required therein. Please be advised that Rosen Laws failure to comply is punishable by contempt. 228 East 45th Street 100 North Biscayne Blvd Suite 1110 Suite 1607 New York, NY 10017 Miami, FL 33132 Tel: (212) 587-5971 Tel: (305) 672-7495 Fax: (212) 658-9852 Fax: (305) 718-0647 www.DavidoffLawFirm.com FILED: NASSAU COUNTY CLERK 09/23/2023 04:04 PM INDEX NO. 602826/2022 NYSCEF DOC. NO. 147 RECEIVED NYSCEF: 09/23/2023 Should Rosen Law LLC have any question regarding any of the disclosures, please contact us at the information on the prior page. You may also contract the undersigned at 212-587-5971. Very truly yours, Jonathan Marc Davidoff, Esq. Counsel for Plaintiff/Judgment Creditor Ben-Zion Alcalay Enclosures: • Subpoena Duces Tecum to Rosen Law, LLC • Supreme Court of the State of New York, County of Nassau, Judgment against Barry Dynkin and Atlas Cybersecurity, LLC, dated May 18, 2023 • Judgment of the Circuit Court of the 15th Judicial Circuit in and for Palm Beach County Florida dated December 7, 2021 cc: Barry Dynkin and Atlas Cybersecurity, LLC Page 2 of 2 DAVIDOFF LAW FIRM, PLLC 228 East 45th Street, Suite 1110, New York, NY 10017 ● Telephone (212) 587-5971 ● Fax (212) 658-9852