Preview
NO.
HFH CAPITAL, LLC IN THE DISTRICT COURT
vs. § MONTGOMERY COUNTY, TEXAS
§
COUNTUP LLC and
BRENDON JAYSHON CONNER § JUDICIAL DISTRICT
PETITION
—_—— TO
SESENFORC
EEEE ENIIGN
FOREIGN VUDGME
JUDGMENT
NT
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, HFH CAPITAL, LLC, (hereinafter referred to as "Plaintiff"), and files
this Petition to Enforce Foreign Judgment in accordance with the Uniform Enforcement ofForeign
Judgments Act (Tex. Civ. Prac. & Rem. Code Ann. § 35.001 to 35.008), against COUNTU
P LLC
and BRENDON JAYSHON CONNER (hereinafter referred to as "Defendants"), and for cause
of action shows the Court as follows:
1 Plaintiff is a corporation organized and existing under the laws of the State of New
York whose principal place of business is located at 6010 New Utrecht Avenue, Brooklyn, NY
11219.
2 On the 11" day of January, 2023, in the Supreme Court, County of Kings, State of
New York, in a cause of action numbered 535100/2022, styled HFH CAPITAL, LLC VS.
COUNTUP LLC and BRENDON JAYSHON CONNER, judgment was entered against the
Defendants and for the Plaintiff in accordance with the following: Judgment was entered of record
in favor of HFH CAPITAL, LLC in the principal amount of Thirty-Eight Thousand, One Hundred
Sixty-Four and 14/100 Dollars ($38,164.14). A duly-certified, attested, and authenticated copy of
the Judgment in that cause of action is attached as Exhibit "A" and incorporated herein by
reference. The Judgment is final, valid, and collectable.
WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that the authenticated copy of
Judgment be filed in accordance with the provisions of Tex. Civ. Prac. & Rem. Code Ann. § 35.001
to § 35.008, that the authenticated and attested Foreign Judgment be domesticated in the
State of
Texas, thereby having the same force and effect as if rendered in this honorable state.
Respectfully submitted,
ALAN R. §CHEINTHAL
TBC # 17736640
Attorney at Law
4635 Southwest Freeway, Suite 720
Houston, Texas 77027
(713) 871-8040
(713) 871-8642 Telecopier
ascheinthal@ScheinthalLawFirm.com
ATTORNEY FOR PLAINTIFF,
HFH CAPITAL, LLC
No. 4666830
=
THEPEOPLE NEW-YORK
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No. 4666829
Be,
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Certification
STATE OF NEW YORK, COUNTY OF KINGS, SS
|, Nancy T. Sunshine, County er and I rk f Sunrempe Court King county,
is
do hereby certify that on April 1: aes { have compared
the foc ent a ad ‘geet,
535100/2022; Judg , filed 1/03/2023 page(s) 1-3
with the: originals filed i in my office and the same.is‘a gore
3s sth
therefrom and of the whole ‘of'such original nies
Lf i h.
whereto bhave affixed my HY id. sal.
Cg 2 Lord
NANCY T. SUNSHINE
KINGS COUNTY CLERK
Ur
a Bal i Rina fi ry 2m ‘WET: _
NYACEP DOG, NO,
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
HFH CAPITAL LLC,
Index No.: 535100/2022
Plaintiff,
JUDGMENT
-against-
COUNTUP LLC AND BRENDON JAYSHON
CONNER,
Defendants. _
The summons and complaint in this action having been served upon Defendants and
proofs of service thereof having been filed with the Court and additional copies of the
summons and complaint having been mailed to defendants pursuant to CPLR 3215 (g)(3)G)
and CPLR 3215 (g)(4)(i), and defendants having failed to appear, answer or raise an
objection to the complaint in point of law, and the time for to defendants to do so having
expired.
NOW, on motion of Zachter PLLC attorneys for the plaintiff, it is ADJUDGED that
plaintiff, HFH CAPITAL LLC, located at 6010 New Utrecht Avenue, Brooklyn, NY 11219, have
judgment and recover from defendant COUNTUP LLC, located at 2001 Timberloch Pl Ste 500
The Woodlands, TX 77380 and defendant BRENDON JAYSHON CONNER, residing at 2001
‘Timberloch PI Ste 500 The Woodlands, TX 77380, the sum of $36,125.01, plus interest from
July 22, 2022 in the amount of $1,544.13, together with $495 in costs and disbursements as
taxed by the Clerk, amountinin
g all to the sum of $38,164.14 and that plaintiff have execution
therefor.
2 furghire
CLERK
FILED
2023 JAN 11 PM 2:56
KINGS COUNTY CLERK
FEE
1 of 3
Pm
NVACHH
xrnaa-Qhery-cumer-
NOC NO yw
LEZ LPP tems
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
HFH CAPITAL LLC,
Index No. 535100/2022
Plaintiff,
BILL OF COSTS
-against-
COUNTUP LLC AND BRENDON JAYSHON
CONNER,
Defendants.
DISBURSEMENTS
Fee for Index Numbev............ $210
CPLR §8018(a)
Costs by Statute............. $200
Default Judgment Filing Fee............ $45
Sherriff Execution ........... $40
TOTAL
sisscsssssssssseerssscssseecesss
$495
es
STATE OF NEW YORK,
SS.
Attorney's Affirmation
COUNTY OF NEW YORK
The undersigned, an attorney admitted to practice in the courts of this State, is the
Principal at Zachter PLLC, the attorneys of record for the plaintiff in the above entitled action;
and affirms that the foregoing disbursements have been or will necessarily be made or
incurred in this action and are reasonable in amount. The undersigned affirms that the
foregoing statements are true, under penalties of perjury.
Dated: New York, New York
January 9, 2023
Jeffrey Zac
FILED
2023 JAN 11 PM 2:56
KINGS COUNTY CLERK
FEE
ies En Tee
nae NO. vt
OL TESS STOR
SUPREME COURT OF THE STATE
OF NEW YORK
COUNTY OF KINGS
x
HFH CAPITAL LLC,
Index No. 535100/2022
Plaintiff
-against-
COUNTUP LLC AND BRE NDON JAY
SHON
CONNER,
Defendants.
x
JUDGMENT and BILL OF COSTS
a= <=
ZACHTER PLLC
30 Wall Street, 8th Floor
New York, New York 10005
(646) 779-3294
Mail To:
2 University Plaza, Suite 205
Hackensack, New Jersey 07601
(201) 500- 6576
Attorneys for Plaintiff
3 of 3
Peres RTE —
All which we ¢...
hi by these Pre: ito be exemplified, seal of our said
Court for said County to be hereunto affixe
WITNESS, HON. Hon. Toussaint
#25
A Justice of our Supreme Court ij for the Second Judicial District of said State,
I this bf /
“]
2 barf
Clerk.
I Hon. Wavny Toussaint
a Justice of the Supreme Court
of the Stato Si York in and | Secon yucoral District thereof, do hereby certify, that
Nano 6 unshine, whose nam bscribod to the preceding exemplification, Is the Clerk
te. nity
i isKings,
" and
fe due to her,
Supreme Court in and for sald County, and that full
Gots,
| FURTHER CERTIFY, th; Seal affixed to said exemplification is the proper Seal of said
Court of said County, and le attestation thereof is in due form of law and by the proper
officer.
WITNESS my h; he Borough of Brooklyn,
thi: is
(Hh day of, in the year 20 3
/
Preview
NO. HFH CAPITAL, LLC IN THE DISTRICT COURT vs. § MONTGOMERY COUNTY, TEXAS § COUNTUP LLC and BRENDON JAYSHON CONNER § JUDICIAL DISTRICT PETITION —_—— TO SESENFORC EEEE ENIIGN FOREIGN VUDGME JUDGMENT NT TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, HFH CAPITAL, LLC, (hereinafter referred to as "Plaintiff"), and files this Petition to Enforce Foreign Judgment in accordance with the Uniform Enforcement ofForeign Judgments Act (Tex. Civ. Prac. & Rem. Code Ann. § 35.001 to 35.008), against COUNTU P LLC and BRENDON JAYSHON CONNER (hereinafter referred to as "Defendants"), and for cause of action shows the Court as follows: 1 Plaintiff is a corporation organized and existing under the laws of the State of New York whose principal place of business is located at 6010 New Utrecht Avenue, Brooklyn, NY 11219. 2 On the 11" day of January, 2023, in the Supreme Court, County of Kings, State of New York, in a cause of action numbered 535100/2022, styled HFH CAPITAL, LLC VS. COUNTUP LLC and BRENDON JAYSHON CONNER, judgment was entered against the Defendants and for the Plaintiff in accordance with the following: Judgment was entered of record in favor of HFH CAPITAL, LLC in the principal amount of Thirty-Eight Thousand, One Hundred Sixty-Four and 14/100 Dollars ($38,164.14). A duly-certified, attested, and authenticated copy of the Judgment in that cause of action is attached as Exhibit "A" and incorporated herein by reference. The Judgment is final, valid, and collectable. WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that the authenticated copy of Judgment be filed in accordance with the provisions of Tex. Civ. Prac. & Rem. Code Ann. § 35.001 to § 35.008, that the authenticated and attested Foreign Judgment be domesticated in the State of Texas, thereby having the same force and effect as if rendered in this honorable state. Respectfully submitted, ALAN R. §CHEINTHAL TBC # 17736640 Attorney at Law 4635 Southwest Freeway, Suite 720 Houston, Texas 77027 (713) 871-8040 (713) 871-8642 Telecopier ascheinthal@ScheinthalLawFirm.com ATTORNEY FOR PLAINTIFF, HFH CAPITAL, LLC No. 4666830 = THEPEOPLE NEW-YORK BY DE GaSe DER ND: IN! be +i Toall to.whom these Presen: come, GREETING hey we sbeete We sted the files and reco rds.in the oF ings, at Broa| Kyinain id oul j 00/ a Oa a a kate ts tt file oron record in the words and figures fol at ¥ i Se took t tne Gy ct a ee C7 i Ke UX se oF) aS AL a No. 4666829 Be, By. ity iin te g* Certification STATE OF NEW YORK, COUNTY OF KINGS, SS |, Nancy T. Sunshine, County er and I rk f Sunrempe Court King county, is do hereby certify that on April 1: aes { have compared the foc ent a ad ‘geet, 535100/2022; Judg , filed 1/03/2023 page(s) 1-3 with the: originals filed i in my office and the same.is‘a gore 3s sth therefrom and of the whole ‘of'such original nies Lf i h. whereto bhave affixed my HY id. sal. Cg 2 Lord NANCY T. SUNSHINE KINGS COUNTY CLERK Ur a Bal i Rina fi ry 2m ‘WET: _ NYACEP DOG, NO, SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS HFH CAPITAL LLC, Index No.: 535100/2022 Plaintiff, JUDGMENT -against- COUNTUP LLC AND BRENDON JAYSHON CONNER, Defendants. _ The summons and complaint in this action having been served upon Defendants and proofs of service thereof having been filed with the Court and additional copies of the summons and complaint having been mailed to defendants pursuant to CPLR 3215 (g)(3)G) and CPLR 3215 (g)(4)(i), and defendants having failed to appear, answer or raise an objection to the complaint in point of law, and the time for to defendants to do so having expired. NOW, on motion of Zachter PLLC attorneys for the plaintiff, it is ADJUDGED that plaintiff, HFH CAPITAL LLC, located at 6010 New Utrecht Avenue, Brooklyn, NY 11219, have judgment and recover from defendant COUNTUP LLC, located at 2001 Timberloch Pl Ste 500 The Woodlands, TX 77380 and defendant BRENDON JAYSHON CONNER, residing at 2001 ‘Timberloch PI Ste 500 The Woodlands, TX 77380, the sum of $36,125.01, plus interest from July 22, 2022 in the amount of $1,544.13, together with $495 in costs and disbursements as taxed by the Clerk, amountinin g all to the sum of $38,164.14 and that plaintiff have execution therefor. 2 furghire CLERK FILED 2023 JAN 11 PM 2:56 KINGS COUNTY CLERK FEE 1 of 3 Pm NVACHH xrnaa-Qhery-cumer- NOC NO yw LEZ LPP tems SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS HFH CAPITAL LLC, Index No. 535100/2022 Plaintiff, BILL OF COSTS -against- COUNTUP LLC AND BRENDON JAYSHON CONNER, Defendants. DISBURSEMENTS Fee for Index Numbev............ $210 CPLR §8018(a) Costs by Statute............. $200 Default Judgment Filing Fee............ $45 Sherriff Execution ........... $40 TOTAL sisscsssssssssseerssscssseecesss $495 es STATE OF NEW YORK, SS. Attorney's Affirmation COUNTY OF NEW YORK The undersigned, an attorney admitted to practice in the courts of this State, is the Principal at Zachter PLLC, the attorneys of record for the plaintiff in the above entitled action; and affirms that the foregoing disbursements have been or will necessarily be made or incurred in this action and are reasonable in amount. The undersigned affirms that the foregoing statements are true, under penalties of perjury. Dated: New York, New York January 9, 2023 Jeffrey Zac FILED 2023 JAN 11 PM 2:56 KINGS COUNTY CLERK FEE ies En Tee nae NO. vt OL TESS STOR SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS x HFH CAPITAL LLC, Index No. 535100/2022 Plaintiff -against- COUNTUP LLC AND BRE NDON JAY SHON CONNER, Defendants. x JUDGMENT and BILL OF COSTS a= <= ZACHTER PLLC 30 Wall Street, 8th Floor New York, New York 10005 (646) 779-3294 Mail To: 2 University Plaza, Suite 205 Hackensack, New Jersey 07601 (201) 500- 6576 Attorneys for Plaintiff 3 of 3 Peres RTE — All which we ¢... hi by these Pre: ito be exemplified, seal of our said Court for said County to be hereunto affixe WITNESS, HON. Hon. Toussaint #25 A Justice of our Supreme Court ij for the Second Judicial District of said State, I this bf / “] 2 barf Clerk. I Hon. Wavny Toussaint a Justice of the Supreme Court of the Stato Si York in and | Secon yucoral District thereof, do hereby certify, that Nano 6 unshine, whose nam bscribod to the preceding exemplification, Is the Clerk te. nity i isKings, " and fe due to her, Supreme Court in and for sald County, and that full Gots, | FURTHER CERTIFY, th; Seal affixed to said exemplification is the proper Seal of said Court of said County, and le attestation thereof is in due form of law and by the proper officer. WITNESS my h; he Borough of Brooklyn, thi: is (Hh day of, in the year 20 3 /