Preview
FILED: KINGS COUNTY CLERK 01/05/2024 04:28 PM INDEX NO. 525985/2023
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 01/05/2024
EXHIBIT A
FILED: KINGS COUNTY CLERK 01/05/2024
12/11/2023 04:28
11:23 PM
AM INDEX NO. 525985/2023
NYSCEF DOC. NO. 16
14 RECEIVED NYSCEF: 01/05/2024
12/11/2023
At an IAS Part_[2,,of the
SupretiteCógrt of theState
Of New York, held in and for
The County·ofKings, at the
Courthouse.thereof, located at
360 Adams Street,Ramrt23;
Brooklyn, NY 11201 on the day
or December 8 ,2023.
PTESENT: HON. Ellen M. Spodek , JSC
SÚPREME CO.URTOF THE STATE OF NEW ŽORK
COUNTY OF KINGS
------------÷-----r-----•-------------------------X INDEX ÑO. 525985/2023
ACE FUNDING SOURCE LLCs
ORDER
TO SHO€ CAUSE
Plaintiff,
SRC/D .
-agamst-
GOOD GRACES LLC d/b/a/ GOOD GRACES
PHARMACY, BRANDON KEITH GREGORY
and BOBBI S GREGORY,
Defendants.
___..........................___----.--.._....__.....................________X
U15on reading and filing the annexed affirmation.of MarcdCaridi, Esq., affirmed
November 14, 2023, and upon the exhibits annexed hereto.;
Let Defendants GOOD GRACES LLC d/b/a GOOD GRACES PHAXMACY,.
BRANDON KIETH GREGORY and BOBBI S GREGORY, show cause at an IAS Part 73
before the Hon. presiding justice to be held at the Suprerne Court Building, KINGS
8th
County, 360.Adams Street, Room 761, Brooklyn, NY11201 on the day of January . 2024, at
9:30 a.in. in the forenoon or as soorr thereafter as Counsel ean.be heard why an Order should not
be made and entered:
A) bischarging the.Law Office or Caridi P.C..as attorneys of record for Defendant;
B)$taying all 13roceedings for 60 days; and
1 of 2
FILED: KINGS COUNTY CLERK 01/05/2024
12/11/2023 04:28
11:23 PM
AM INDEX NO. 525985/2023
NYSCEF DOC. NO. 16
14 RECEIVED NYSCEF: 01/05/2024
12/11/2023
C) Together with such other and further relief us this Court.deems just and proper
SUFFICIENT cause appearing therefore, let delivery of this Order with supporting papers upon
which it is based be served upoit Defendants BRANDON KEITH GREGORY and BOBBI S
GREGORY and upon Esq,,-5½-
by personal service Plaintiff's Attorney, Erica R.Gilerman,
overnight mail
Madison-Aw,-Strite-8-F0A--NerYork-NY-t@22 via NYSGEF or before 21st day of
December, 2023 bedeemed good and sufficient.
ENTER,
JUZTICE O xNE SUPREl E COURT
2 of 2
FILED: KINGS COUNTY CLERK 01/05/2024
11/14/2023 04:28
10:42 PM
AM INDEX NO. 525985/2023
NYSCEF DOC. NO. 16
12 RECEIVED NYSCEF: 01/05/2024
11/14/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
---------------------------------------------------------------X INDEX NO. 525985/2023
ACE FUNDING SOURCE LLC,
AFFIRMATION
IN SUPPORT
Plaintiff,
-against-
GOOD GRACES LLC d/b/a GOOD GRACES
PHARMACY, BRANDON KEITH GREGORY
and BOBBI S GREGORY
Defendants.
_________________________________________________________________Ç
Marco R. Caridi, Esq., an attorney duly admitted to practice before the Courts of the State
of New York, hereby affirms, under the penalties of perjury, that:
1. I am an attorney at the Law Office of Caridi, PC. the attorneys of record for Defendant
GOOD GRACES LLC d/b/a GOOD GRACES PHARMACY, BRANDON KEITH
GREGORY and BOBBI S GREGORY. I make this affirmation in support of my
application to be discharged as attorney of record for the Defendants. I ask that all
matters be stayed for 60 days so that Defendants may have the opportunity to seek new
counsel.
("Defendants'
2. The Law Office of Caridi PC Counsel") entered an appearance in this
matter on behalf of the Defendants upon the filing of an Answer, Affirmative Defenses
and Counterclaims (collectively, the "Answer") on or about October 12, 2023.
3. I have devoted numerous hours on this file and have been more than generous with my
time and resources.
4. Our continued relationship is wholly untenable. I have made every possible effort to
assist DEFENDANT, but I cannot continue as counsel under the circumstances.
1 of 2
FILED: KINGS COUNTY CLERK 01/05/2024
11/14/2023 04:28
10:42 PM
AM INDEX NO. 525985/2023
NYSCEF DOC. NO. 16
12 RECEIVED NYSCEF: 01/05/2024
11/14/2023
5. No prior application for the relief requested herein has been made.
WHEREFORE, it is respectfully requested that this court discharge the firm of The Law
Office of Caridi PC as the attorneys of record for DEFENDANTS and staying all
proceedings for 60 days, together with such other and further relief as this Court deems just
and proper.
Dated: November 14, 2023 LAW OFFICE OF CARIDI, PC
Brooklyn, NY Attorneys for Defendants
Marco R Caridi, Esq.
4*
9809 Avenue
Brooklyn, New York 11209
Tel: 917-698-7105
Email: mrcaridi@aol.com
2 of 2
Preview
FILED: KINGS COUNTY CLERK 01/05/2024 04:28 PM INDEX NO. 525985/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 01/05/2024 EXHIBIT A FILED: KINGS COUNTY CLERK 01/05/2024 12/11/2023 04:28 11:23 PM AM INDEX NO. 525985/2023 NYSCEF DOC. NO. 16 14 RECEIVED NYSCEF: 01/05/2024 12/11/2023 At an IAS Part_[2,,of the SupretiteCógrt of theState Of New York, held in and for The County·ofKings, at the Courthouse.thereof, located at 360 Adams Street,Ramrt23; Brooklyn, NY 11201 on the day or December 8 ,2023. PTESENT: HON. Ellen M. Spodek , JSC SÚPREME CO.URTOF THE STATE OF NEW ŽORK COUNTY OF KINGS ------------÷-----r-----•-------------------------X INDEX ÑO. 525985/2023 ACE FUNDING SOURCE LLCs ORDER TO SHO€ CAUSE Plaintiff, SRC/D . -agamst- GOOD GRACES LLC d/b/a/ GOOD GRACES PHARMACY, BRANDON KEITH GREGORY and BOBBI S GREGORY, Defendants. ___..........................___----.--.._....__.....................________X U15on reading and filing the annexed affirmation.of MarcdCaridi, Esq., affirmed November 14, 2023, and upon the exhibits annexed hereto.; Let Defendants GOOD GRACES LLC d/b/a GOOD GRACES PHAXMACY,. BRANDON KIETH GREGORY and BOBBI S GREGORY, show cause at an IAS Part 73 before the Hon. presiding justice to be held at the Suprerne Court Building, KINGS 8th County, 360.Adams Street, Room 761, Brooklyn, NY11201 on the day of January . 2024, at 9:30 a.in. in the forenoon or as soorr thereafter as Counsel ean.be heard why an Order should not be made and entered: A) bischarging the.Law Office or Caridi P.C..as attorneys of record for Defendant; B)$taying all 13roceedings for 60 days; and 1 of 2 FILED: KINGS COUNTY CLERK 01/05/2024 12/11/2023 04:28 11:23 PM AM INDEX NO. 525985/2023 NYSCEF DOC. NO. 16 14 RECEIVED NYSCEF: 01/05/2024 12/11/2023 C) Together with such other and further relief us this Court.deems just and proper SUFFICIENT cause appearing therefore, let delivery of this Order with supporting papers upon which it is based be served upoit Defendants BRANDON KEITH GREGORY and BOBBI S GREGORY and upon Esq,,-5½- by personal service Plaintiff's Attorney, Erica R.Gilerman, overnight mail Madison-Aw,-Strite-8-F0A--NerYork-NY-t@22 via NYSGEF or before 21st day of December, 2023 bedeemed good and sufficient. ENTER, JUZTICE O xNE SUPREl E COURT 2 of 2 FILED: KINGS COUNTY CLERK 01/05/2024 11/14/2023 04:28 10:42 PM AM INDEX NO. 525985/2023 NYSCEF DOC. NO. 16 12 RECEIVED NYSCEF: 01/05/2024 11/14/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ---------------------------------------------------------------X INDEX NO. 525985/2023 ACE FUNDING SOURCE LLC, AFFIRMATION IN SUPPORT Plaintiff, -against- GOOD GRACES LLC d/b/a GOOD GRACES PHARMACY, BRANDON KEITH GREGORY and BOBBI S GREGORY Defendants. _________________________________________________________________Ç Marco R. Caridi, Esq., an attorney duly admitted to practice before the Courts of the State of New York, hereby affirms, under the penalties of perjury, that: 1. I am an attorney at the Law Office of Caridi, PC. the attorneys of record for Defendant GOOD GRACES LLC d/b/a GOOD GRACES PHARMACY, BRANDON KEITH GREGORY and BOBBI S GREGORY. I make this affirmation in support of my application to be discharged as attorney of record for the Defendants. I ask that all matters be stayed for 60 days so that Defendants may have the opportunity to seek new counsel. ("Defendants' 2. The Law Office of Caridi PC Counsel") entered an appearance in this matter on behalf of the Defendants upon the filing of an Answer, Affirmative Defenses and Counterclaims (collectively, the "Answer") on or about October 12, 2023. 3. I have devoted numerous hours on this file and have been more than generous with my time and resources. 4. Our continued relationship is wholly untenable. I have made every possible effort to assist DEFENDANT, but I cannot continue as counsel under the circumstances. 1 of 2 FILED: KINGS COUNTY CLERK 01/05/2024 11/14/2023 04:28 10:42 PM AM INDEX NO. 525985/2023 NYSCEF DOC. NO. 16 12 RECEIVED NYSCEF: 01/05/2024 11/14/2023 5. No prior application for the relief requested herein has been made. WHEREFORE, it is respectfully requested that this court discharge the firm of The Law Office of Caridi PC as the attorneys of record for DEFENDANTS and staying all proceedings for 60 days, together with such other and further relief as this Court deems just and proper. Dated: November 14, 2023 LAW OFFICE OF CARIDI, PC Brooklyn, NY Attorneys for Defendants Marco R Caridi, Esq. 4* 9809 Avenue Brooklyn, New York 11209 Tel: 917-698-7105 Email: mrcaridi@aol.com 2 of 2