Preview
FILED: MONROE COUNTY CLERK 03/01/2024 01:45 PM INDEX NO. E2024003942
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/01/2024
MONROE COUNTY CLERK’S OFFICE THIS IS NOT A BILL. THIS IS YOUR RECEIPT.
Receipt # 3765266
Book Page CIVIL
Return To: No. Pages: 8
JACOB ISRAEL VERSTANDIG
290 Central Avenue Instrument: EFILING INDEX NUMBER
Lawrence, NY 11559
Control #: 202403011183
Index #: E2024003942
Date: 03/01/2024
MERK FUNDING INC d/b/a CAP ASSIST Time: 2:37:28 PM
ONE MIKE DETROIT, LLC
MOORE, KIMBERLY IRENE
State Fee Index Number $165.00
County Fee Index Number $26.00
State Fee Cultural Education $14.25
State Fee Records $4.75 Employee: CW
Management
Total Fees Paid: $210.00
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
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FILED: MONROE COUNTY CLERK 03/01/2024 01:45 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/01/2024
SUPREME COURT OF THE STATE OF NEW YORK Index No.:
COUNTY OF MONROE
MERK FUNDING INC d/b/a CAP ASSIST,
Plaintiff, SUMMONS
-against-
Plaintiff’s address:
ONE MIKE DETROIT, LLC and 2071 Flatbush Avenue Ste 6
KIMBERLY IRENE MOORE, Brooklyn, New York 11234
Defendants.
TO THE ABOVE-NAMED DEFENDANTS:
YOU ARE HEREBY SUMMONED and required to serve upon Plaintiff’s attorneys, at the
address stated below, an answer to the attached complaint. If this summons was personally
delivered upon you in the State of New York, the answer must be served within twenty days after
such service of the summons, excluding the date of service. If the summons was not personally
delivered to you within the State of New York, the answer must be served within thirty days after
service of the summons is complete as provided by law.
If you do not serve an answer to the attached complaint within the applicable time limitation
stated above, a judgment may be entered against you, by default, for the relief demanded in the
complaint, without further notice to you.
Basis for venue: Contractual.
Dated: Lawrence, New York ______________________
February 29, 2024
Jacob Verstandig, Esq.
Nature of this action: breach of contract. Ershowsky Verstandig PLLC
Relief sought: money damages. Attorneys for Plaintiff
290 Central Avenue, Suite 109
Lawrence, New York 11559
Phone: (516) 400-7163
Email: collections@evlawpllc.com
Defendants to be served:
One Mike Detroit, LLC
16870 Prevost St, Detroit, Michigan 48235
Kimberly Irene Moore
16870 Prevost St, Detroit, Michigan 48235
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FILED: MONROE COUNTY CLERK 03/01/2024 01:45 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/01/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF MONROE
MERK FUNDING INC d/b/a CAP ASSIST, Index No.:
Plaintiff,
-against- VERIFIED
COMPLAINT
ONE MIKE DETROIT, LLC and
KIMBERLY IRENE MOORE,
Defendants.
Plaintiff Merk Funding Inc d/b/a Cap Assist (“Plaintiff”'), by its attorneys, Ershowsky
Verstandig PLLC, for its complaint herein against One Mike Detroit, LLC (“Company
Defendant”) and Kimberly Irene Moore (“Moore”) (Company Defendant and Moore shall be
collectively referred to as “Defendants”), alleges as follows:
The Parties
1. At all relevant times, Plaintiff was and is a Delaware Corporation authorized to conduct
business in New York.
2. Upon information and belief, at all relevant times, Company Defendant was and is a
company organized and existing under the laws of the State of Michigan.
3. Upon information and belief, at all relevant times, Moore was and is an individual
residing in the State of Michigan.
4. Moore is the owner, principal, and/or manager of Company Defendant.
AS AND FOR THE FIRST CAUSE OF ACTION (Breach of Contract)
5. On or about February 2, 2024, Defendants executed a written settlement agreement (the
“Agreement”) whereby they agreed to pay Plaintiff $53,615.00.
6. Defendants made payments of only $18,737.50 under the Agreement before defaulting
on February 26, 2024 by not making the scheduled payment, leaving a balance remaining of
$41,522.50. In addition, pursuant to the Agreement, Defendants incurred a default fee in the
amount of $10,380.62, calculated at twenty-Five Percent (25%) of the remaining balance due.
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/01/2024
7. During the course of the Agreement, the unpaid sums became due and payable to
Plaintiff, in full as required by Plaintiff or pursuant to the terms of the Agreement in the event of any
action constituting a default or breach of any of covenants or warranties contained in the Agreement.
Any outstanding balance owed by the Company Defendant at the time of default became
immediately due and payable.
8. By reason of the foregoing, Plaintiff has suffered damages in the amount of $51,903.12,
plus interest at the statutory rate, costs, disbursements and attorney's fees.
WHEREFORE, Plaintiff requests judgement against Defendants, jointly and severally, as follows:
(i) On the first cause of action of the complaint, Plaintiff requests judgement against each
Defendant, jointly and severally, in the amount of $51,903.12, plus interest at the statutory rate, costs,
disbursements and attorney’s fees;
(ii) For such other and further relief as this Court deems just and proper.
Dated: February 29, 2024 _______________________
Jacob Verstandig, Esq.
Ershowsky Verstandig PLLC
Attorneys for Plaintiff
290 Central Avenue, Suite 109
Lawrence, New York 11559
Phone: (516) 400-7163
Email: collections@evlawpllc.com
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FILED: MONROE COUNTY CLERK 03/01/2024 01:45 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/01/2024
SUPREME COURT OF THE STATE OF NEW YORK Index No.:
COUNTY OF MONROE
MERK FUNDING INC d/b/a CAP ASSIST, VERIFICATION
Plaintiff, BY A PARTY
-against-
ONE MIKE DETROIT, LLC and
KIMBERLY IRENE MOORE,
Defendants.
STATE OF NEW YORK )
)
COUNTY OF KINGS )
Boruch Orzel, being duly sworn states that he is an Authorized Officer of Plaintiff in
the within action. I have read the foregoing Verified Complaint and know the contents thereof;
the same is true to my own knowledge, except as to matters therein stated to be alleged on
information and belief, and as to those matters, I believe them to be true.
The foregoing statements are true under penalties of perjury.
Boruch Orzel
Boruch Orzel, _______________________
Boruch Orzel (Feb 29, 2024 20:11 EST)
2-29-24 before me personally appeared Boruch Orzel, personally known to me or proved to me on the basis
On _________,
of satisfactory evidence to be the individual whose name is subscribed to the within instrument and acknowledged
to me that he executed the same in his capacity, and that by his signature on the instrument, the individual, or the
person or entity upon behalf of which the individual acted, executed the instrument.
________________
ro och (Feb 29, 2024 20:14 EST)
Notary Public
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FILED: MONROE COUNTY CLERK 03/01/2024 01:45 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/01/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF MONROE
MERK FUNDING INC d/b/a CAP ASSIST, Index No.:
Plaintiff,
-against-
ONE MIKE DETROIT, LLC and
KIMBERLY IRENE MOORE,
Defendants.
NOTICE OF ELECTRONIC FILING
(Consensual Case)
(Uniform Rule §202.5-b)
YOU HAVE RECEIVED THIS NOTICE because:
1) The Plaintiff/Petitioner, whose name is listed above, has filed this case using the New
York State Courts E-filing system (“NYSCEF”), and
2) You are a Defendant/Respondent (a party) in this case.
• If you are represented by an attorney:
Give this Notice to your attorney. (Attorneys: see “Information for Attorneys” pg. 2).
• If you are not represented by an attorney:
You will be served with all documents in paper and you must serve and file your
documents in paper, unless you choose to participate in e-filing.
If you choose to participate in e-filing, you must have access to a computer and a scanner
or other device to convert documents into electronic format, a connection to the internet,
and an e-mail address to receive service of documents.
The benefits of participating in e-filing include:
• serving and filing your documents electronically
• free access to view and print your e-filed documents
• limiting your number of trips to the courthouse
• paying any court fees on-line (credit card needed)
To register for e-filing or for more information about how e-filing works:
• visit: www.nycourts.gov/efile-unrepresented or
• contact the Clerk’s Office or Help Center at the court where the case was filed. Court contact
information can be found at www.nycourts.gov
To find legal information to help you represent yourself visit www.nycourthelp.gov.
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/01/2024
Information for Attorneys
An attorney representing a party who is served with this notice must either consent or decline consent
to electronic filing and service through NYSCEF for this case.
Attorneys registered with NYSCEF may record their consent electronically in the manner provided
at the NYSCEF site. Attorneys not registered with NYSCEF but intending to participate in e-filing
must first create a NYSCEF account and obtain a user ID and password prior to recording their
consent by going to www.nycourts.gov/efile
Attorneys declining to consent must file with the court and serve on all parties of record a declination
of consent.
For additional information about electronic filing and to create a NYSCEF account, visit the
NYSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource Center (phone:
646-386-3033; e-mail: efile@nycourts.gov).
Dated: February 29, 2024
_______________________
Jacob Verstandig, Esq.
Ershowsky Verstandig PLLC
Attorneys for Plaintiff
290 Central Avenue, Suite 109
Lawrence, New York 11559
Phone: (516) 400-7163
Email: collections@evlawpllc.com
To:
One Mike Detroit, LLC
16870 Prevost St
Detroit, Michigan 48235
Kimberly Irene Moore
16870 Prevost St
Detroit, Michigan 48235
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FILED: MONROE COUNTY CLERK 03/01/2024 01:45 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/01/2024
Index No. Year: 2024 Hon.
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF MONROE
MERK FUNDING INC d/b/a CAP ASSIST,
Plaintiff,
-against-
ONE MIKE DETROIT, LLC and
KIMBERLY IRENE MOORE,
Defendants.
SUMMONS, VERIFIED COMPLAINT and NOTICE OF ELECTRONIC FILING
Ershowsky Verstandig PLLC
Attorneys for Plaintiff
Office and Post Office Address, Telephone
290 Central Avenue, Suite 109
Lawrence, New York 11559
Phone: (516) 400-7163
Email: collections@evlawpllc.com
Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the courts of New York State,
certifies that, upon information and belief and reasonable inquiry, the contentions contained in the annexed document
are not frivolous.
Dated: February 29, 2024
Lawrence, New York
_______________________
Jacob Verstandig, Esq.
To:
Attorney(s) for
Service of a copy of the within is hereby admitted.
Dated:
Attorney(s) for
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Preview
FILED: MONROE COUNTY CLERK 03/01/2024 01:45 PM INDEX NO. E2024003942 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/01/2024 MONROE COUNTY CLERK’S OFFICE THIS IS NOT A BILL. THIS IS YOUR RECEIPT. Receipt # 3765266 Book Page CIVIL Return To: No. Pages: 8 JACOB ISRAEL VERSTANDIG 290 Central Avenue Instrument: EFILING INDEX NUMBER Lawrence, NY 11559 Control #: 202403011183 Index #: E2024003942 Date: 03/01/2024 MERK FUNDING INC d/b/a CAP ASSIST Time: 2:37:28 PM ONE MIKE DETROIT, LLC MOORE, KIMBERLY IRENE State Fee Index Number $165.00 County Fee Index Number $26.00 State Fee Cultural Education $14.25 State Fee Records $4.75 Employee: CW Management Total Fees Paid: $210.00 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 1 of 8 202403011183 03/01/2024 02:37:28 PM CIVIL 202403011183 INDEX NO. E2024003942 FILED: MONROE COUNTY CLERK 03/01/2024 01:45 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/01/2024 SUPREME COURT OF THE STATE OF NEW YORK Index No.: COUNTY OF MONROE MERK FUNDING INC d/b/a CAP ASSIST, Plaintiff, SUMMONS -against- Plaintiff’s address: ONE MIKE DETROIT, LLC and 2071 Flatbush Avenue Ste 6 KIMBERLY IRENE MOORE, Brooklyn, New York 11234 Defendants. TO THE ABOVE-NAMED DEFENDANTS: YOU ARE HEREBY SUMMONED and required to serve upon Plaintiff’s attorneys, at the address stated below, an answer to the attached complaint. If this summons was personally delivered upon you in the State of New York, the answer must be served within twenty days after such service of the summons, excluding the date of service. If the summons was not personally delivered to you within the State of New York, the answer must be served within thirty days after service of the summons is complete as provided by law. If you do not serve an answer to the attached complaint within the applicable time limitation stated above, a judgment may be entered against you, by default, for the relief demanded in the complaint, without further notice to you. Basis for venue: Contractual. Dated: Lawrence, New York ______________________ February 29, 2024 Jacob Verstandig, Esq. Nature of this action: breach of contract. Ershowsky Verstandig PLLC Relief sought: money damages. Attorneys for Plaintiff 290 Central Avenue, Suite 109 Lawrence, New York 11559 Phone: (516) 400-7163 Email: collections@evlawpllc.com Defendants to be served: One Mike Detroit, LLC 16870 Prevost St, Detroit, Michigan 48235 Kimberly Irene Moore 16870 Prevost St, Detroit, Michigan 48235 2 of 8 202403011183 03/01/2024 02:37:28 PM CIVIL 202403011183 INDEX NO. E2024003942 FILED: MONROE COUNTY CLERK 03/01/2024 01:45 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/01/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF MONROE MERK FUNDING INC d/b/a CAP ASSIST, Index No.: Plaintiff, -against- VERIFIED COMPLAINT ONE MIKE DETROIT, LLC and KIMBERLY IRENE MOORE, Defendants. Plaintiff Merk Funding Inc d/b/a Cap Assist (“Plaintiff”'), by its attorneys, Ershowsky Verstandig PLLC, for its complaint herein against One Mike Detroit, LLC (“Company Defendant”) and Kimberly Irene Moore (“Moore”) (Company Defendant and Moore shall be collectively referred to as “Defendants”), alleges as follows: The Parties 1. At all relevant times, Plaintiff was and is a Delaware Corporation authorized to conduct business in New York. 2. Upon information and belief, at all relevant times, Company Defendant was and is a company organized and existing under the laws of the State of Michigan. 3. Upon information and belief, at all relevant times, Moore was and is an individual residing in the State of Michigan. 4. Moore is the owner, principal, and/or manager of Company Defendant. AS AND FOR THE FIRST CAUSE OF ACTION (Breach of Contract) 5. On or about February 2, 2024, Defendants executed a written settlement agreement (the “Agreement”) whereby they agreed to pay Plaintiff $53,615.00. 6. Defendants made payments of only $18,737.50 under the Agreement before defaulting on February 26, 2024 by not making the scheduled payment, leaving a balance remaining of $41,522.50. In addition, pursuant to the Agreement, Defendants incurred a default fee in the amount of $10,380.62, calculated at twenty-Five Percent (25%) of the remaining balance due. 3 of 8 202403011183 03/01/2024 02:37:28 PM CIVIL 202403011183 INDEX NO. E2024003942 FILED: MONROE COUNTY CLERK 03/01/2024 01:45 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/01/2024 7. During the course of the Agreement, the unpaid sums became due and payable to Plaintiff, in full as required by Plaintiff or pursuant to the terms of the Agreement in the event of any action constituting a default or breach of any of covenants or warranties contained in the Agreement. Any outstanding balance owed by the Company Defendant at the time of default became immediately due and payable. 8. By reason of the foregoing, Plaintiff has suffered damages in the amount of $51,903.12, plus interest at the statutory rate, costs, disbursements and attorney's fees. WHEREFORE, Plaintiff requests judgement against Defendants, jointly and severally, as follows: (i) On the first cause of action of the complaint, Plaintiff requests judgement against each Defendant, jointly and severally, in the amount of $51,903.12, plus interest at the statutory rate, costs, disbursements and attorney’s fees; (ii) For such other and further relief as this Court deems just and proper. Dated: February 29, 2024 _______________________ Jacob Verstandig, Esq. Ershowsky Verstandig PLLC Attorneys for Plaintiff 290 Central Avenue, Suite 109 Lawrence, New York 11559 Phone: (516) 400-7163 Email: collections@evlawpllc.com 4 of 8 202403011183 03/01/2024 02:37:28 PM CIVIL 202403011183 INDEX NO. E2024003942 FILED: MONROE COUNTY CLERK 03/01/2024 01:45 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/01/2024 SUPREME COURT OF THE STATE OF NEW YORK Index No.: COUNTY OF MONROE MERK FUNDING INC d/b/a CAP ASSIST, VERIFICATION Plaintiff, BY A PARTY -against- ONE MIKE DETROIT, LLC and KIMBERLY IRENE MOORE, Defendants. STATE OF NEW YORK ) ) COUNTY OF KINGS ) Boruch Orzel, being duly sworn states that he is an Authorized Officer of Plaintiff in the within action. I have read the foregoing Verified Complaint and know the contents thereof; the same is true to my own knowledge, except as to matters therein stated to be alleged on information and belief, and as to those matters, I believe them to be true. The foregoing statements are true under penalties of perjury. Boruch Orzel Boruch Orzel, _______________________ Boruch Orzel (Feb 29, 2024 20:11 EST) 2-29-24 before me personally appeared Boruch Orzel, personally known to me or proved to me on the basis On _________, of satisfactory evidence to be the individual whose name is subscribed to the within instrument and acknowledged to me that he executed the same in his capacity, and that by his signature on the instrument, the individual, or the person or entity upon behalf of which the individual acted, executed the instrument. ________________ ro och (Feb 29, 2024 20:14 EST) Notary Public 5 of 8 202403011183 03/01/2024 02:37:28 PM CIVIL 202403011183 INDEX NO. E2024003942 FILED: MONROE COUNTY CLERK 03/01/2024 01:45 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/01/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF MONROE MERK FUNDING INC d/b/a CAP ASSIST, Index No.: Plaintiff, -against- ONE MIKE DETROIT, LLC and KIMBERLY IRENE MOORE, Defendants. NOTICE OF ELECTRONIC FILING (Consensual Case) (Uniform Rule §202.5-b) YOU HAVE RECEIVED THIS NOTICE because: 1) The Plaintiff/Petitioner, whose name is listed above, has filed this case using the New York State Courts E-filing system (“NYSCEF”), and 2) You are a Defendant/Respondent (a party) in this case. • If you are represented by an attorney: Give this Notice to your attorney. (Attorneys: see “Information for Attorneys” pg. 2). • If you are not represented by an attorney: You will be served with all documents in paper and you must serve and file your documents in paper, unless you choose to participate in e-filing. If you choose to participate in e-filing, you must have access to a computer and a scanner or other device to convert documents into electronic format, a connection to the internet, and an e-mail address to receive service of documents. The benefits of participating in e-filing include: • serving and filing your documents electronically • free access to view and print your e-filed documents • limiting your number of trips to the courthouse • paying any court fees on-line (credit card needed) To register for e-filing or for more information about how e-filing works: • visit: www.nycourts.gov/efile-unrepresented or • contact the Clerk’s Office or Help Center at the court where the case was filed. Court contact information can be found at www.nycourts.gov To find legal information to help you represent yourself visit www.nycourthelp.gov. 6 of 8 202403011183 03/01/2024 02:37:28 PM CIVIL 202403011183 INDEX NO. E2024003942 FILED: MONROE COUNTY CLERK 03/01/2024 01:45 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/01/2024 Information for Attorneys An attorney representing a party who is served with this notice must either consent or decline consent to electronic filing and service through NYSCEF for this case. Attorneys registered with NYSCEF may record their consent electronically in the manner provided at the NYSCEF site. Attorneys not registered with NYSCEF but intending to participate in e-filing must first create a NYSCEF account and obtain a user ID and password prior to recording their consent by going to www.nycourts.gov/efile Attorneys declining to consent must file with the court and serve on all parties of record a declination of consent. For additional information about electronic filing and to create a NYSCEF account, visit the NYSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource Center (phone: 646-386-3033; e-mail: efile@nycourts.gov). Dated: February 29, 2024 _______________________ Jacob Verstandig, Esq. Ershowsky Verstandig PLLC Attorneys for Plaintiff 290 Central Avenue, Suite 109 Lawrence, New York 11559 Phone: (516) 400-7163 Email: collections@evlawpllc.com To: One Mike Detroit, LLC 16870 Prevost St Detroit, Michigan 48235 Kimberly Irene Moore 16870 Prevost St Detroit, Michigan 48235 7 of 8 202403011183 03/01/2024 02:37:28 PM CIVIL 202403011183 INDEX NO. E2024003942 FILED: MONROE COUNTY CLERK 03/01/2024 01:45 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/01/2024 Index No. Year: 2024 Hon. SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF MONROE MERK FUNDING INC d/b/a CAP ASSIST, Plaintiff, -against- ONE MIKE DETROIT, LLC and KIMBERLY IRENE MOORE, Defendants. SUMMONS, VERIFIED COMPLAINT and NOTICE OF ELECTRONIC FILING Ershowsky Verstandig PLLC Attorneys for Plaintiff Office and Post Office Address, Telephone 290 Central Avenue, Suite 109 Lawrence, New York 11559 Phone: (516) 400-7163 Email: collections@evlawpllc.com Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the courts of New York State, certifies that, upon information and belief and reasonable inquiry, the contentions contained in the annexed document are not frivolous. Dated: February 29, 2024 Lawrence, New York _______________________ Jacob Verstandig, Esq. To: Attorney(s) for Service of a copy of the within is hereby admitted. Dated: Attorney(s) for 8 of 8