Preview
FILED
10/9/2023 11:30 AM
FELICIA PITRE
PER AT Y DISTRICT CLERK
DALLAS CO., TEXAS
Christi Underwood DEPUTY
DC-23-17611
NO.
MANTIS FUNDING, LLC § IN THE DISTRICT COURT
VS. DALLAS COUNTY, TEXAS
44th
YBYB TRUCKING LLC and
RICHARD CROCKETT LEE, JR. JUDICIAL DISTRICT
PETITION TO ENFORCE FOREIGN JUDGMENT
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, MANTIS FUNDING, LLC, (hereinafter referred to as "Plaintiff"), and
files this Petition to Enforce Foreign Judgment in accordance with the Uniform Enforcement of
Foreign Judgments Act (Tex. Civ. Prac. & Rem. Code Ann. § 35.001 to 35.008), against YBYB
TRUCKING LLC and RICHARD CROCKETT LEE, JR. (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 64 Beaver Street, Suite 344, New York, NY
10004.
2 On the 9" day of June, 2022, in the Supreme Court of the State of New York,
County of Kings, in a cause of action numbered 512843/2022, styled MANTIS FUNDING, LLC
VS. YBYB TRUCKING LLC and RICHARD CROCKETT LEE, JR., judgment was entered
against the Defendants and for the Plaintiff in accordance with the following: Judgment was
entered of record in favor of MANTIS FUNDING, LLC in the principal amount of Thirty-Eight
Thousand, One Hundred Thirty-Seven and 85/100 Dollars ($38,137.85), plus interest, and court
costs. 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 SCHEINTHAL
TBC # 736640
Attorney at Law
4635 Southwest Freeway, Suite 720
Houston, Texas 77027
(713) 871-8040
(713) 871-8642 Telecopier
scheinthal@ScheinthalLawFirm.cor
ATTORNEY FOR PLAINTIFF
—
ee
No, 4615388
THE PE
Hk
TATEOF NEW, YORK
v Hee
ih AS
R EE AND INDE,
$4
$a
a
To all these Prese y come, GREETING
A Poh
pvt
ak ay Aeaeeeahy
* py at we have inspected the files and records in the
of the Clerk of the County of Kings, at Brooklyn, in said
unty, and do find a certain
#512843/2022, Judgment ©
athe Nn file or on record in the words and figures
An
“hy
AR
EXHIBIT
{i
es
oY, 1A
ne
Certification
STATE OF NEW YORK, COUNTY OF KINGS, SS
|, Nancy T. Sunshine, County Clerk and Clerk of Supreme Court Kings County,
do hereby certify that on July 26, 2022 | have compared
the document attached hereto,
#512843/2022, Judgment, filed 6/09/2022 page(s) 1-3
with the originals filed in my office and the same is'a correct atedripe
4
therefrom re of the whole of such original, in Withiess
whereto |Ihave affixed my signature and seal.
Pouey 2 Her hor
NANCY T. SUNSHINE
KINGS COUNTY CLERK
eos mis
sae peasy a
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS im
MANTIS FUNDING LLC,
Index No.: $12843/2022
Plaintiff,
JUDGMENT
-against-
YBYB TRUCKING LLC AND RICHARD CROCKETT
LEE, JR,
ise ren EE
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)(i)
and CPLR 3215 (g)(4)(i), and defendants having failed vo 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, MANTIS FUNDING LLC, located at 64 Beaver Street, Suite 344,
New York, NW 10004,
have judgment and recover from defendant YBYB TRUCKING
LLC _ located at 1645 Sky High
Cir Dallas, TX 75253 and defendant RICHARD CROCKETT LEE,
JR, residing at 1645 Sky High
Cir Dallas, TX 75253, the sum of $36,680, plus interest from
February 24, 2022 in the amount
of $962.85, together with $495 in costs and disbursements as
taxed by the Clerk, amounting
in all to the sum of $38,137.85 and that plaintiff have execution
therefor.
FILED Howey 2 thevahire
2022 JUN 09 AM 11:03
KINGS COUNTY CLERK
FEE
1 of 3
aia
i Bee
wy
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS .
MANTIS FUNDING LLC,
Index No. 512843/2022
Plaintiff,
BILL OF COSTS
-against-
YBYB TRUCKING LLC AND RICHARD
CROCKETT LEE, JR,
DISBURSEMENTS
Fee for Index Number $210
CPLR §8018(a)}
Costs by Statute... $200
Default Judgment Filing Fee $45
Sherriff Execution .......... $40
TOTAL 2 2 an $495
STATE OF NEW YORK,
SS.
Attorney’s Affirmation
COUNTY OF NEW YORK
The undersigned, an attorney admitted to practice in the court
s of this State, is the
Principal at Zachter PLLC, the attorneys of record for the plaintiffin
the above entitled action;
and affirms that the foregoing disburse ments have been or will
necessarily be made or
incurred in this action and are reasonable in amou mt.
The undersigned affirms that the
foregoing statements are true, under penalties of perj ary.
Dated: New York, New York
June B, 2022
Jeffrey Zach; y
2 of 3
Sees
ee
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS xX
MANTIS FUNDING LLC, -
Index No. 512843/2022
Plaintiff
-against-
YBYB TRUCKING LLC AND RICHARD
CROCKETT LEE, JR,
_..Defendants
JUDGMENT and BILL OF COSTS
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
All forw hichsaid weCounty
a
| aus! ese Pro: bG bd, if seal of our sald
Court to be hereunto affixed
WITNESS, HON. Hon. Silber
A Justice of our Supreme Court i or the Second Judicial District of said State,
this igh Av gV5t 200-e
rai
a Of (ipré 6 Court In and for 6
falth and credit are dus to her} acts.
| FURTHER CERTIFY, th: Seal affixed to said exemplification is the proper Seal of said
Court of said County, and t! B attestation thereof is in due form of law and by the proper
officer.
WITNESS my hag e Borough of Brooklyn,this
lo™ day of fe st, in the year 2077U
-—7 ob
A Justice of the Supreme Court of the State of New York
in and for the Second Judicial District.
ron. Debra Silber
Tou) 2 ler
Ned
Clerk.
Bie
|, Nancy T., Ine, Clerk of the County of Kings, and also of the Supreme Court of said
County in lor the Second Judicial District of said State (said Court being a Court of
Record), reby certify, that Hon. Hon. Debra Silber whose
name is, ribed to the foregoing certificate, is a Justice of the Supreme Court of said State
in and § e Second Judicial District, duly elected and sworn, and that the signature of said
aid Certificate is genuine.
ONY WHEREOF, I have hereunto set my hand and affixed the Seal of said Cour
day of ary ver in the vear 20°72
am"
Mu ? dar fn
te
Clerk.
NO.
MANTIS FUNDING, LLC § IN THE DISTRICT COURT
§
VS. § DALLAS COUNTY, TEXAS
§
§
YBYB TRUCKING LLC and §
RICHARD CROCKETT LEE, JR. § JUDICIAL DISTRICT
AFFIDAVIT OF FILING FOREIGN JUDGMENT
PURSUANT TO ENFORCEMENT OF FOREIGN JUDGMENT ACT
THE STATE OF TEXAS §
§
COUNTY OF HARRIS §
BEFORE ME, the undersigned authority, personally appeared Alan R. Scheinthal, known
to me to be a credible person competent in all respects to make this Affidavit, and who, being by
me sworn under oath, stated:
"I am the attorney for the Judgment Creditor in the Judgment dated June 9, 2022,
rendered by the Supreme Court of the State of New York, County of Kings. An
authenticated copy of the Judgment has this day been filed with the Clerk of the
above-captioned court.
"The names and last-known address of the Judgment Debtor is:
YBYB TRUCKING LLC and RICHARD CROCKETT LEE, JR.
1645 Sky High Cirle
Dallas, Texas 75253
“The address of the Judgment Creditor is:
MANTIS FUNDING, LLC
64 Beaver Street, Suite 344
New York, New York 10004
"The name and address of the Judgment Creditor's attorney in Texas is
Alan R. Scheinthal
State Bar No. 17736640
4635 Southwest Freeway, Suite 720
Houston, Texas 77027
"The purpose of this Affidavit is so that notice of the filing of the Foreign Judgment
can be given to the Judgment Debtors."
SIGNED on this the (th day of September 2023.
Alan R. yn
SUBSCRIBED AND SWORN TO before me, this l ot day of September 2023, to which
certify my hand and official seal.
[
Ai te Schearthal
JULI HARTHAN SCHEINTHAL
Notary ID #1325498
39
Public, State of Texas
My Commission Expires
July 1, 2024
Preview
FILED 10/9/2023 11:30 AM FELICIA PITRE PER AT Y DISTRICT CLERK DALLAS CO., TEXAS Christi Underwood DEPUTY DC-23-17611 NO. MANTIS FUNDING, LLC § IN THE DISTRICT COURT VS. DALLAS COUNTY, TEXAS 44th YBYB TRUCKING LLC and RICHARD CROCKETT LEE, JR. JUDICIAL DISTRICT PETITION TO ENFORCE FOREIGN JUDGMENT TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, MANTIS FUNDING, LLC, (hereinafter referred to as "Plaintiff"), and files this Petition to Enforce Foreign Judgment in accordance with the Uniform Enforcement of Foreign Judgments Act (Tex. Civ. Prac. & Rem. Code Ann. § 35.001 to 35.008), against YBYB TRUCKING LLC and RICHARD CROCKETT LEE, JR. (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 64 Beaver Street, Suite 344, New York, NY 10004. 2 On the 9" day of June, 2022, in the Supreme Court of the State of New York, County of Kings, in a cause of action numbered 512843/2022, styled MANTIS FUNDING, LLC VS. YBYB TRUCKING LLC and RICHARD CROCKETT LEE, JR., judgment was entered against the Defendants and for the Plaintiff in accordance with the following: Judgment was entered of record in favor of MANTIS FUNDING, LLC in the principal amount of Thirty-Eight Thousand, One Hundred Thirty-Seven and 85/100 Dollars ($38,137.85), plus interest, and court costs. 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 SCHEINTHAL TBC # 736640 Attorney at Law 4635 Southwest Freeway, Suite 720 Houston, Texas 77027 (713) 871-8040 (713) 871-8642 Telecopier scheinthal@ScheinthalLawFirm.cor ATTORNEY FOR PLAINTIFF — ee No, 4615388 THE PE Hk TATEOF NEW, YORK v Hee ih AS R EE AND INDE, $4 $a a To all these Prese y come, GREETING A Poh pvt ak ay Aeaeeeahy * py at we have inspected the files and records in the of the Clerk of the County of Kings, at Brooklyn, in said unty, and do find a certain #512843/2022, Judgment © athe Nn file or on record in the words and figures An “hy AR EXHIBIT {i es oY, 1A ne Certification STATE OF NEW YORK, COUNTY OF KINGS, SS |, Nancy T. Sunshine, County Clerk and Clerk of Supreme Court Kings County, do hereby certify that on July 26, 2022 | have compared the document attached hereto, #512843/2022, Judgment, filed 6/09/2022 page(s) 1-3 with the originals filed in my office and the same is'a correct atedripe 4 therefrom re of the whole of such original, in Withiess whereto |Ihave affixed my signature and seal. Pouey 2 Her hor NANCY T. SUNSHINE KINGS COUNTY CLERK eos mis sae peasy a SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS im MANTIS FUNDING LLC, Index No.: $12843/2022 Plaintiff, JUDGMENT -against- YBYB TRUCKING LLC AND RICHARD CROCKETT LEE, JR, ise ren EE 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)(i) and CPLR 3215 (g)(4)(i), and defendants having failed vo 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, MANTIS FUNDING LLC, located at 64 Beaver Street, Suite 344, New York, NW 10004, have judgment and recover from defendant YBYB TRUCKING LLC _ located at 1645 Sky High Cir Dallas, TX 75253 and defendant RICHARD CROCKETT LEE, JR, residing at 1645 Sky High Cir Dallas, TX 75253, the sum of $36,680, plus interest from February 24, 2022 in the amount of $962.85, together with $495 in costs and disbursements as taxed by the Clerk, amounting in all to the sum of $38,137.85 and that plaintiff have execution therefor. FILED Howey 2 thevahire 2022 JUN 09 AM 11:03 KINGS COUNTY CLERK FEE 1 of 3 aia i Bee wy SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS . MANTIS FUNDING LLC, Index No. 512843/2022 Plaintiff, BILL OF COSTS -against- YBYB TRUCKING LLC AND RICHARD CROCKETT LEE, JR, DISBURSEMENTS Fee for Index Number $210 CPLR §8018(a)} Costs by Statute... $200 Default Judgment Filing Fee $45 Sherriff Execution .......... $40 TOTAL 2 2 an $495 STATE OF NEW YORK, SS. Attorney’s Affirmation COUNTY OF NEW YORK The undersigned, an attorney admitted to practice in the court s of this State, is the Principal at Zachter PLLC, the attorneys of record for the plaintiffin the above entitled action; and affirms that the foregoing disburse ments have been or will necessarily be made or incurred in this action and are reasonable in amou mt. The undersigned affirms that the foregoing statements are true, under penalties of perj ary. Dated: New York, New York June B, 2022 Jeffrey Zach; y 2 of 3 Sees ee SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS xX MANTIS FUNDING LLC, - Index No. 512843/2022 Plaintiff -against- YBYB TRUCKING LLC AND RICHARD CROCKETT LEE, JR, _..Defendants JUDGMENT and BILL OF COSTS 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 All forw hichsaid weCounty a | aus! ese Pro: bG bd, if seal of our sald Court to be hereunto affixed WITNESS, HON. Hon. Silber A Justice of our Supreme Court i or the Second Judicial District of said State, this igh Av gV5t 200-e rai a Of (ipré 6 Court In and for 6 falth and credit are dus to her} acts. | FURTHER CERTIFY, th: Seal affixed to said exemplification is the proper Seal of said Court of said County, and t! B attestation thereof is in due form of law and by the proper officer. WITNESS my hag e Borough of Brooklyn,this lo™ day of fe st, in the year 2077U -—7 ob A Justice of the Supreme Court of the State of New York in and for the Second Judicial District. ron. Debra Silber Tou) 2 ler Ned Clerk. Bie |, Nancy T., Ine, Clerk of the County of Kings, and also of the Supreme Court of said County in lor the Second Judicial District of said State (said Court being a Court of Record), reby certify, that Hon. Hon. Debra Silber whose name is, ribed to the foregoing certificate, is a Justice of the Supreme Court of said State in and § e Second Judicial District, duly elected and sworn, and that the signature of said aid Certificate is genuine. ONY WHEREOF, I have hereunto set my hand and affixed the Seal of said Cour day of ary ver in the vear 20°72 am" Mu ? dar fn te Clerk. NO. MANTIS FUNDING, LLC § IN THE DISTRICT COURT § VS. § DALLAS COUNTY, TEXAS § § YBYB TRUCKING LLC and § RICHARD CROCKETT LEE, JR. § JUDICIAL DISTRICT AFFIDAVIT OF FILING FOREIGN JUDGMENT PURSUANT TO ENFORCEMENT OF FOREIGN JUDGMENT ACT THE STATE OF TEXAS § § COUNTY OF HARRIS § BEFORE ME, the undersigned authority, personally appeared Alan R. Scheinthal, known to me to be a credible person competent in all respects to make this Affidavit, and who, being by me sworn under oath, stated: "I am the attorney for the Judgment Creditor in the Judgment dated June 9, 2022, rendered by the Supreme Court of the State of New York, County of Kings. An authenticated copy of the Judgment has this day been filed with the Clerk of the above-captioned court. "The names and last-known address of the Judgment Debtor is: YBYB TRUCKING LLC and RICHARD CROCKETT LEE, JR. 1645 Sky High Cirle Dallas, Texas 75253 “The address of the Judgment Creditor is: MANTIS FUNDING, LLC 64 Beaver Street, Suite 344 New York, New York 10004 "The name and address of the Judgment Creditor's attorney in Texas is Alan R. Scheinthal State Bar No. 17736640 4635 Southwest Freeway, Suite 720 Houston, Texas 77027 "The purpose of this Affidavit is so that notice of the filing of the Foreign Judgment can be given to the Judgment Debtors." SIGNED on this the (th day of September 2023. Alan R. yn SUBSCRIBED AND SWORN TO before me, this l ot day of September 2023, to which certify my hand and official seal. [ Ai te Schearthal JULI HARTHAN SCHEINTHAL Notary ID #1325498 39 Public, State of Texas My Commission Expires July 1, 2024