Exhibit,Appendix: Blueberry Funding Ll C Vs Moshe Leor

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                                OCN-L-001301-23            2023-08-28 14:07:34.061       Pglof3      Trans ID: LCV20232454981




Leor Moshe
437 Brentwood Avenue
Toms River, New Jersey 08755
Pro Se

Blueberry Funding, LLC

                             Plaintiff,                               Superior Court of New       Jersey
                                                                      Law Division
                                                                                VS.
                                                                                       Ocean County

                                                                      Docket # L-1301-23
Leor Moshe,        120 Whitesville LLC,
John Does 1-10 (Fictitiously named), XYZ
Corporations 1-10 fictitiously named
                                                                      ANSWER ON BEHALF OF
                             Defendants.                              LEOR MOSHE
poten nnn nn nn nn nnn nnn   nnn nee.                 sas


             Defendant, Leor Moshe, as and for his Answer to Plaintiff's Complaint, states as

follows:

             1        Denies    knowledge    sufficient     to support    the     allegations   contained   in

Paragraph | of the Complaint.

         2         Admits the allegations contained in Paragraph 2 of the Complaint.

         3           Denies     knowledge    sufficient     to support    the     allegations   contained   in
Paragraph 3 of the Complaint.

                                            BACKGROUND

         4         Denies the allegations contained in Paragraph 4 of the Complaint, although

admits that certain defendants executed certain Promissory Notes that were void based
                                                                                      on
OCN-L-001301-23           2023-08-28 14:07:34.061     Pg2of3    Trans ID: LCV20232454981




public policy since they called for usurious interest rates for as much as 50%.

         5          Denies the allegations contained in Paragraph 5 of the Complaint, although

admits       that certain   individuals or entities,   including entities not named   here,   received

monies from Plaintiff.

         6         Admits the allegations contained in Paragraph 6 of the Complaint to the

extent that it alleges that monies were repaid, denies, however, the repayments totaled

only $1 million.

         7         Denies the allegations contained in Paragraph 7 of the Complaint.

                                                 VENUE

         8         Admits the allegations contained in Paragraph 8 of the Complaint.

                                             FIRST COUNT

         9         Defendant incorporates by reference his answers to paragraphs | through 8

as if they were set forth here.

         10.       Denies the allegations contained in Paragraph 10 of the Complaint

         ll        Denies the allegations contained in Paragraph 11 of the Complaint

         12        Denies the allegations contained in Paragraph 12 of the Complaint

         13        Denies the allegations contained in Paragraph 13 of the Complaint

                      AS AND FOR A         FIRST AFFIRMATIVE DEFENSE

         14        The Complaint fails, in whole or in part, to state a claim upon which relief

maybe granted.
OCN-L-001301-23      2023-08-28 14:07:34.061    Pg 3o0f3   Trans ID: LCV20232454981




                AS AND FOR A SECOND AFFIRMATIVE DEFENSE

        15.    Any injury or damage which may have been suffered by plaintiffs resulted

wholly or in substantial part from their own conduct and/or negligence.

                 AS AND FOR A THIRD AFFIRMATIVE                    DEFENSE

        16.   Plaintiff's claims are barred, in whole or in part, by the doctrines of waiver,

estoppel and unclean hands.

               AS AND FOR A FOURTH AFFIRMATIVE                      DEFENSE

        Tf.    Plaintiff's claim is barred as a result of violations by plaintiff and its agents

or assigns, of the Fair Debt Collection Practices Act.

                 AS AND FOR A FIFTH AFFIRMATIVE                    DEFENSE

       18.        Defendant reserves his right to allege additional affirmative defenses

revealed through discovery.

       WHEREFORE,          Defendant    Leor   Moshe     demands   judgment     dismissing   the

Complaint in its entirety and for such other and further relief as this Court may deem just

and proper.

Dated: New York, New York
       August 28, 2023




                                                                   Leor Moshe