Preview
FILED: RICHMOND COUNTY CLERK 03/15/2024 03:59 PM INDEX NO. 150540/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/15/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF RICHMOND
____________________________________________________________Ç
NORTHFIELD BANK, Index No.:
Plaintiff, SUMMONS
-against-
JOE NY CONSULTING, INC. d/b/a UPSTATE
CONSULTING and RIFKY EPSTEIN
Defendants.
________________________________________________________Ç
TO THE ABOVE NAMED DEFENDANTS:
YOU ARE HEREBY SUMMONED and required to serve upon plaintiff s attorney an answer
within twenty (20) days after the service of this summons, exclusive of the day of service, or
within thirty (30) days after service is complete if this summons is not personally delivered to
you within the State of New York.
In case of your failure to answer, judgment will be taken against you by default for the relief
demanded in the complaint.
The basis of the venue designated is the location of the transaction which form the basis of this
action.
Dated: Staten Island, New York
March 15, 2024
CRAWFORD DESANTIS MANCUSO, LLP
A lyn J. fo d, Esq.
Att ys for Plaintiff
NORTHFIELD BANK
900 South Avenue, Suite 204
Staten Island, New York 10314
718-273-9414
TO: JOE NY CONSULTING, INC
d /a UPSTATE CONSULTING
34 Franklin Avenue, Suite 314
Brooklyn, New York 11205
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FILED: RICHMOND COUNTY CLERK 03/15/2024 03:59 PM INDEX NO. 150540/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/15/2024
RIFKY EPSTEIN
204 Skillman Street
Brooklyn, New York 11205
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FILED: RICHMOND COUNTY CLERK 03/15/2024 03:59 PM INDEX NO. 150540/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/15/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF RICHMOND
-----------------------------------------------------------------x Index No.:
NORTHFIELD BANK,
NOTICE OF MOTION
Plaintiff, FOR SUMMARY
JUDGMENT IN LIEU OF
-against- COMPLAINT
JOE NY CONSULTING, INC. d/b/a UPSTATE
CONSULTING and RIFKY EPSTEIN
Defendants.
_____________________________--__________________________________Ç
Upon the summons, dated March 15, 2024, the affidavit of Douglas Cummings sworn to
on March 14, 2024, and the affirmation of Allyn J. Crawford, Esq., dated March 15, 2024,
together with all the exhibits thereto, plaintiff Northfield Bank ("Plaintiff") will move this Court
at the Supreme Court Courthouse, 18 Richmond Terrace, Staten Island, New York 10301 on
May 30, 2024 at 9:30 a.m., or as soon thereafter as counsel may be heard, for an order granting
Plaintiff summary judgment in lieu of complaint and entering a judgment as against Defendants
in the principal amount of $136,359.26 plus interest from January 1, 2024 at the rate of 11.5%
per annum through entry of judgment and the legal fees and costs incurred by Plaintiff, and for
such other and further relief as to this Court may seem just and proper, upon the ground that this
action is based upon instruments for the payment of money only which is due and payable.
TAKE FURTHER NOTICE, that all answering papers shall be served on the undersigned
so as to be received at least seven (7) days before the return date.
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FILED: RICHMOND COUNTY CLERK 03/15/2024 03:59 PM INDEX NO. 150540/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/15/2024
Dated: Staten Island, New York
March 15, 2024
Yours, etc.
CRAWFORD DESANTIS MANCUSO, LLP
All . wford, Esq.
Attorneys for Plaintiff
NORTHFIELD BANK
900 South Avenue, Suite 204
Staten Island, New York 10314
(718) 273-9414
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