On May 17, 2023 a
Letter,Correspondence
was filed
involving a dispute between
Ebf Holdings, Llc
Dba Everest Business Funding,
and
Naeb Tekeste John,
Us Marine Transportation Llc,
for Other Matters - Contract - Other
in the District Court of Monroe County.
Preview
INDEX NO. E2023005189
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 01/12/2024
MIA
1 of 2
FLEEH?°HONROE
COUNTY CLERK 0171272024 02:48 PM INDE&& NOE 2623025085 189
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 01/12/2024
C IO
Cj
January 12, 2024
Re: Outstanding Discovery: EBF PARTNERS, LLC D/B/A EVEREST BUSINESS FUNDING v.
US MARINE TRANSPORTATION LLC etal
Index No.: E2023005189
Y our Honor,
As you are aware, this office represents the interests of the Plaintiff in the above-referenced
matter. Upon the discovery demands we propounded upon the defendant and per the Court Order
dated November 27, 2023, the defendants were to produce certain documents with respect to the
Revenue Purchase A greement entered into between the parties by December 31, 2023.
In particular, we note that the Defendants have failed to provide financial statements
requested in This office is requesting an extension to file the Note
of Issue and Certificate of Readiness as discovery disputes have not been resolved.
Thank you for your attention to this matter.
Sincerely,
/_Avith Bouskila
Ariel Bouskila, Esq.
212-729-1477x301
ari@ bblawpllc.com
Sent Via NYSCEF
BERKOVITCH & BOUSKILA PLLC
1545 U.S. 202 | Suite 101 | Pomona, NY 10970
Phone, 212.729.1477 | Fax. 347.342.3192
2 of 2
Document Filed Date
January 12, 2024
Case Filing Date
May 17, 2023
Category
Other Matters - Contract - Other
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INDEX NO. E2023005189 NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 01/12/2024 MIA 1 of 2 FLEEH?°HONROE COUNTY CLERK 0171272024 02:48 PM INDE&& NOE 2623025085 189 NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 01/12/2024 C IO Cj January 12, 2024 Re: Outstanding Discovery: EBF PARTNERS, LLC D/B/A EVEREST BUSINESS FUNDING v. US MARINE TRANSPORTATION LLC etal Index No.: E2023005189 Y our Honor, As you are aware, this office represents the interests of the Plaintiff in the above-referenced matter. Upon the discovery demands we propounded upon the defendant and per the Court Order dated November 27, 2023, the defendants were to produce certain documents with respect to the Revenue Purchase A greement entered into between the parties by December 31, 2023. In particular, we note that the Defendants have failed to provide financial statements requested in This office is requesting an extension to file the Note of Issue and Certificate of Readiness as discovery disputes have not been resolved. Thank you for your attention to this matter. Sincerely, /_Avith Bouskila Ariel Bouskila, Esq. 212-729-1477x301 ari@ bblawpllc.com Sent Via NYSCEF BERKOVITCH & BOUSKILA PLLC 1545 U.S. 202 | Suite 101 | Pomona, NY 10970 Phone, 212.729.1477 | Fax. 347.342.3192 2 of 2