On June 23, 2023 a
Exhibit,Appendix
was filed
involving a dispute between
Ebf Holdings, Llc
D B A Everest Business Funding,
and
Julio Cesar Londono,
Julio Cesar Londono
D B A Distribuidora Del Valle,
for Other Matters - Contract - Other
in the District Court of Monroe County.
Preview
FILED: MONROE COUNTY CLERK 01/12/2024 05:12 PM INDEX NO. E2023006654
NYSCEF DOC. NO. 96 RECEIVED NYSCEF: 01/12/2024
MONROE COUNTY CLERK’S OFFICE THIS IS NOT A BILL. THIS IS YOUR RECEIPT.
Receipt # 3705789
Book Page CIVIL
Return To: No. Pages: 2
ARIEL BOUSKILA
1545 US 202 Instrument: EXHIBIT(S)
Suite 101
Pomona, NY 10970 Control #: 202401160705
Index #: E2023006654
Date: 01/16/2024
EBF HOLDINGS, LLC Time: 11:46:39 AM
JULIO CESAR LONDONO
LONDONO, JULIO CESAR
Total Fees Paid: $0.00
Employee:
State of New York
MONROE COUNTY CLERK’S OFFICE
WARNING – THIS SHEET CONSTITUTES THE CLERKS
ENDORSEMENT, REQUIRED BY SECTION 317-a(5) &
SECTION 319 OF THE REAL PROPERTY LAW OF THE
STATE OF NEW YORK. DO NOT DETACH OR REMOVE.
JAMIE ROMEO
MONROE COUNTY CLERK
202401160705 Index #
INDEX : E2023006654
NO. E2023006654
FILED: MONROE COUNTY CLERK 01/12/2024 05:12 PM
NYSCEF DOC. NO. 96 RECEIVED NYSCEF: 01/12/2024
July 14, 2023
To: dominick.dale@gmail.com
Dominick Dale Esq.
Attorney(s) for Defendant
81 Court Street
Brooklyn, NY 11201
( 17) 816-8327
Re: Outstanding Discovery EBF HOLDINGS, LLC v. JULIO
CESAR LONDONO et al INDEX# E2023006654
Dear Mr. Dale,
As you are aware, we represent the Plaintiff in the aforementioned action. Furthermore,
upon the demands we requested, your client was to produce certain documents and responses
with respect to the Revenue Purchase Agreement entered into between the parties, and the
circumstances surrounding the execution thereof.
Specifically, we note that the Defendants have failed to respond Plaintiff’s Demand for
Discovery and Demand for Interrogatories. Please allow this letter to serve as a good faith
attempt to obtain outstanding document discovery, specifically in the manner of financial records
including but not limited to the Merchant’s bank statements, revenue report, and Accounts
Receivables Reports from March 1, 2023, up to the date of production.
In accordance with this office’s discovery demands dated July 5, 2023, please forward
your discovery responses within the next ten (10) days in order to avoid unnecessary
Court intervention.
Thank you for attention to this matter. If you have any questions, please feel free to contact
the undersigned.
Sincerely,
Ariel Bouskila, Esq.
212-729-1477x301
ari@bblawpllc.com
Document Filed Date
January 12, 2024
Case Filing Date
June 23, 2023
Category
Other Matters - Contract - Other
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FILED: MONROE COUNTY CLERK 01/12/2024 05:12 PM INDEX NO. E2023006654 NYSCEF DOC. NO. 96 RECEIVED NYSCEF: 01/12/2024 MONROE COUNTY CLERK’S OFFICE THIS IS NOT A BILL. THIS IS YOUR RECEIPT. Receipt # 3705789 Book Page CIVIL Return To: No. Pages: 2 ARIEL BOUSKILA 1545 US 202 Instrument: EXHIBIT(S) Suite 101 Pomona, NY 10970 Control #: 202401160705 Index #: E2023006654 Date: 01/16/2024 EBF HOLDINGS, LLC Time: 11:46:39 AM JULIO CESAR LONDONO LONDONO, JULIO CESAR Total Fees Paid: $0.00 Employee: State of New York MONROE COUNTY CLERK’S OFFICE WARNING – THIS SHEET CONSTITUTES THE CLERKS ENDORSEMENT, REQUIRED BY SECTION 317-a(5) & SECTION 319 OF THE REAL PROPERTY LAW OF THE STATE OF NEW YORK. DO NOT DETACH OR REMOVE. JAMIE ROMEO MONROE COUNTY CLERK 202401160705 Index # INDEX : E2023006654 NO. E2023006654 FILED: MONROE COUNTY CLERK 01/12/2024 05:12 PM NYSCEF DOC. NO. 96 RECEIVED NYSCEF: 01/12/2024 July 14, 2023 To: dominick.dale@gmail.com Dominick Dale Esq. Attorney(s) for Defendant 81 Court Street Brooklyn, NY 11201 ( 17) 816-8327 Re: Outstanding Discovery EBF HOLDINGS, LLC v. JULIO CESAR LONDONO et al INDEX# E2023006654 Dear Mr. Dale, As you are aware, we represent the Plaintiff in the aforementioned action. Furthermore, upon the demands we requested, your client was to produce certain documents and responses with respect to the Revenue Purchase Agreement entered into between the parties, and the circumstances surrounding the execution thereof. Specifically, we note that the Defendants have failed to respond Plaintiff’s Demand for Discovery and Demand for Interrogatories. Please allow this letter to serve as a good faith attempt to obtain outstanding document discovery, specifically in the manner of financial records including but not limited to the Merchant’s bank statements, revenue report, and Accounts Receivables Reports from March 1, 2023, up to the date of production. In accordance with this office’s discovery demands dated July 5, 2023, please forward your discovery responses within the next ten (10) days in order to avoid unnecessary Court intervention. Thank you for attention to this matter. If you have any questions, please feel free to contact the undersigned. Sincerely, Ariel Bouskila, Esq. 212-729-1477x301 ari@bblawpllc.com