Motion-Secondary: Revenued Llc v. Advice Chaser, Llc, Anthony Tomashefsky

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                                FILED: NASSAU COUNTY CLERK 01/02/2024 08:03 PM                                                    INDEX NO. 615152/2023
NYSCEF DOC. NO. 20                                                                        RECEIVED NYSCEF: 01/02/2024




                             IN THE SUPREME COURT OF NASSAU COUNTY NEW YORK

             In re:                                                  NO. 615152/2023

             REVENUED LLC;                                           AFFIDAVIT OF ANTHONY

                                              Plaintiff;             TOMASHEFSKY IN OPPOSITION

                       Vs.                                           TO PLAINTIFF’S MOTION FOR

             ADVICE CHASER;                                          DEFAULT

             ANTHONY TOMASHEFSKY;

                                              Defendant.



                      1.      Mr. Cohen failed to do basic due diligence as required by the New York Rules

            of Professional Conduct.

                      2.      Mr. Cohen admits he failed to provide proper service. In his reply he states: “it

            appears envelopes were delivered to the original sender on 11/18/2023 (four days prior to the

            date of my affirmation), I have never been supplied with copies those returned envelopes nor

            was I ever informed about those returned envelopes.”

                      3.      On October 3, 2023, Mr. Cohen filed an affidavit of service which included

            USPS tracking numbers. On November 22, 2023, Mr. Cohen filed this motion, and four days

            after his summons and complaint had been returned to him. Mr. Cohen claims he was unaware




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FILED: NASSAU COUNTY CLERK 01/02/2024 08:03 PM                                               INDEX NO. 615152/2023
NYSCEF DOC. NO. 20                                                                    RECEIVED NYSCEF: 01/02/2024




            of this. Apparently, Mr. Cohen does not own a computer, cell phone, or tablet capable of

            visiting USPS.com.

                     4.    Mr. Cohen has an ethical obligation pursuant to the New York Rules of

            Professional Conduct to do due diligence on anything he files in this Court.

                     5.    It would have taken Mr. Cohen no more than 30 seconds to go to the USPS

            website and find that his Summons and Complaint were never served. Mr. Cohen either failed

            to do basic due diligence or he lied to this Court.

                     6.    Revenued is attempting to collect a judgment on an invalid and illegal loan,

            and through a frivolous motion they seek to gain a judgment without giving me an opportunity

            to respond.

                     7.    I respectfully ask the Court to consider entering sanctions against Mr. Cohen.



            SIGNED this 2nd day of January, 2024 at Port Angeles, Washington.

                                                           _________________________
                                                           ANTHONY TOMASHEFKSY




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