Preview
FILED: KINGS COUNTY CLERK 03/26/2024 12:16 PM INDEX NO. 508565/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/26/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
-------------------------------------------------------------------X Index No.
BIZFUND LLC Date Filed:
Plaintiff, SUMMONS
-against- Plaintiff’s place of business:
315 AVENUE U BROOKLYN NY
11223
ADEPT SALES SOLUTIONS & CONSULTING LLC
DBA ALL AMERICAN PROMOTIONS & MARKETING
AND JCW ENTERPRISES,
AND JAMES CLYDE WILSON JR
Defendants.
Basis of venue and place of trial set
at KINGS County:
Pursuant to the agreement
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To the above-named defendants:
YOU ARE HERBY SUMMONED to answer the complaint in this action and to serve a
copy of your answer, or, if the complaint is not served with the summons, to serve a notice of
appearance, on the plaintiff’s attorney within 20 days after the service of this summons,
exclusive of the day of service (or within 30 days after the service is complete if this summons is
not personally delivered to you within the State of New York); and in case of your failure to
appear or answer, judgment will be taken against you by default for the relief demanded in the
complaint.
SCHECHTER LAW OFFICE, PLLC
Dated: Brooklyn, New York
MARCH 26, 2024
By: _____Brian Schechter________________________
Brian Schechter, Esq.
Attorneys for Plaintiff
315 Avenue U
Brooklyn, New York 11223
T: (302) 342-8810
Brian@schechterlegal.com
ADEPT SALES SOLUTIONS & CONSULTING LLC DBA ALL AMERICAN PROMOTIONS &
MARKETING
550 S Watters St STE 131, Allen, Texas, 75013
JCW ENTERPRISES
550 S Watters St STE 131, Allen, Texas, 75013
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JAMES CLYDE WILSON JR
3310 Timberview Rd, Dallas, Texas,75229
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
-------------------------------------------------------------------X
BIZFUND LLC
VERIFIEDCOMPLAINT
Plaintiff,
-against-
ADEPT SALES SOLUTIONS & CONSULTING LLC
DBA ALL AMERICAN PROMOTIONS & MARKETING
AND JCW ENTERPRISES
AND JAMES CLYDE WILSON JR
Defendants.
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Plaintiff, BIZFUND LLC, by its attorney, Schechter Law Office PLLC, complaining of the
Defendants ADEPT SALES SOLUTIONS & CONSULTING LLC DBA ALL AMERICAN
PROMOTIONS & MARKETING AND JCW ENTERPRISES AND JAMES CLYDE WILSON
JR, alleges as follows:
PARTIES
1. Plaintiff, BIZFUND LLC (hereinafter referred to as (“PURCHASER” or
“Plaintiff”) with its principal place of business at 315 AVENUE U BROOKLYN NY
11223 is a Delaware Limited Liability Company.
2. Upon information and belief, Defendant ADEPT SALES SOLUTIONS &
CONSULTING LLC DBA ALL AMERICAN PROMOTIONS & MARKETING AND JCW
ENTERPRISES (hereinafter referred to as “MERCHANT”) is/are a business organized and
existing under the laws of TX located 550 S Watters St STE 131, Allen, Texas, 75013.
3. Defendant JAMES CLYDE WILSON JR (hereinafter referred to as
“PERFORMANCE GUARANTOR(S)”) is/are a natural person and upon information and belief,
at all times hereinafter mentioned, was and is a resident of the state of TX residing at 3310
3 of 10
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Timberview Rd, Dallas, Texas,75229. (MERCHANT and PERFORMANCE GUARANTOR(S)
are hereinafter individually referred to as “Defendant” and collectively referred to as
“Defendants”).
4. Defendants have consented to the jurisdiction of this Court pursuant to the
Agreement referenced below.
AS AND FOR A FIRST CAUSE OF ACTION
AGAINST DEFENDANT MERCHANT
5. Plaintiff repeats and realleges the allegations contained in paragraphs “1” through
“4” above as though fully set forth herein at length.
6. On or about NOVEMBER 2, 2023, PURCHASER entered into a Sales Agreement(s)
with MERCHANT (the “Agreement”) wherein and whereby for the sum of $45,000.00, at the
special instance and request of MERCHANT, PURCHASER agreed to buy and MERCHANT
agreed to sell the future receivables of MERCHANT in the sum of $65,250.00 to be paid by
MERCHANT as an estimated weekly payment of $2,999.00 OR a daily payment of $600
pursuant to the Agreement until paid in full. A true copy of the Agreement is annexed hereto as
Exhibit A.
7. During the course of the Agreement, the unpaid sums become due and payable in
full as required by the Plaintiff or pursuant to the terms of the Agreement on the happening of
any event of default or the breach of any covenants or warranties prescribed under the
Agreement.
8. MERCHANT defaulted under the terms of the Agreement by breaching its
representations and warranties. Additionally, MERCHANT has refused to make all payments
due under the Agreement despite due demand, therefore. All sums due at default become
immediately due and payable.
4 of 10
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9. After all payments, credits, offsets, and deductions, under the Agreement there is
a balance plus contractual fees as of this date in the sum of $44,357.00
10. No payment has been made since MARCH 18, 2024, leaving a balance in the sum
of $44,357.00 plus interest at the statutory rate from MARCH 18, 2024.
11. MERCHANT is currently in default under the terms of the Agreement so that the
balance in the sum of $44,357.00 plus statutory interest from MARCH 18, 2024, is now due and
owing to plaintiff.
12. By reason of the foregoing, MERCHANT is liable to PURCHASER in the sum
$44,357.00 plus interest at the statutory rate from MARCH 18, 2024, through the entry of
judgment herein.
AS AND FOR A SECOND CAUSE OF ACTION
AGAINST DEFENDANT PERFORMANCE GUARANTOR(S)(S)
13. Plaintiff repeats and realleges the allegations contained in paragraphs “1” through
“12” above as though fully set forth herein at length.
14. In connection with the Agreement, PERFORMANCE GUARANTOR(S)(S)
made and delivered to PURCHASER a written personal guarantee of MERCHANT performance
under the Agreement. Said guarantee states: “The undersigned Guarantor(s) hereby irrevocably
and unconditionally guarantees to Purchaser Merchant’s Performance when due. . .” A true copy
of the guarantee is annexed in Exhibit A.
15. Defendant MERCHANT failed to perform under the terms and conditions of the
Agreement, rendering Defendant PERFORMANCE GUARANTOR(S)(S) personally liable
pursuant to the terms of the guarantee.
5 of 10
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16. Defendant PERFORMANCE GUARANTOR(S)(S) is currently in default under
the terms of the Agreement so that the balance in the sum of $44,357.00 plus statutory interest
from MARCH 18, 2024, is now due and owing to plaintiff.
17. By reason of the foregoing, Defendant PERFORMANCE GUARANTOR(S)(S) is
liable to PURCHASER in the sum $44,357.00 plus interest at the statutory rate from MARCH
18, 2024, through the entry of judgment herein.
AS AND FOR A THIRD CAUSE OF ACTION
AGAINST ALL DEFENDANTS
18. Plaintiff repeats and realleges the allegations contained in paragraphs “1” through
“17” above as though fully set forth herein at length.
19. The Agreement provides that in addition to all payments owed under the
Agreement, MERCHANT agrees to pay all costs associated with a breach . . . and the
enforcement thereof, including but not limited to court costs and attorneys’ fees and
disbursements.
20. The guarantee of Defendant PERFORMANCE GUARANTOR(S)(S) provides
that the guarantor shall pay costs, expenses and attorneys’ fees which may be incurred as a result
of the Guarantor’s default under the guarantee.
21. Plaintiff has incurred and continues to incur expenses including attorneys’ fees,
which cannot be finally determined at this date, but which will be capable of determination at
such time as judgment may be entered herein.
22. By reason of the foregoing, Defendants MERCHANT and PERFORMANCE
GUARANTOR(S)(S) are liable to Plaintiff for Plaintiff’s expenses in regard to this litigation,
including attorneys’ fees, in such amount as may be determined.
WHEREFORE, Plaintiff demands judgment:
6 of 10
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/26/2024
a. on the first cause of action against Defendant MERCHANT in the sum of $44,357.00
plus interest at the statutory rate from MARCH 18, 2024, through the entry of judgment
herein;
b. on the second cause of action against Defendant PERFORMANCE GUARANTOR(S) in
the sum of $44,357.00 plus interest at the statutory rate from MARCH 18, 2024, through
the entry of judgment herein;
c. on the third cause of action against Defendants MERCHANT and PERFORMANCE
GUARANTOR(S)(S), jointly and severally awarding Plaintiff attorneys fees together
with costs and expenses incurred in prosecuting this action in an amount to be determined
by the Court.
Dated: Brooklyn, New York
MARCH 26, 2024
SCHECHTER LAW OFFICE, PLLC
By: _______Brian Schechter_____________________
Brian Schechter, Esq.
Attorneys for Plaintiff
315 Avenue U
Brooklyn, New York 11223
T: (302) 342-8810
F: (212) 735-1422
Brian@schechterlegal.com
7 of 10
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VFERIFICATION
STATE OF NEW YORK )
) ss:
COUNTY OF KINGS )
RAYMOND MIZRAHI , being duly sworn deposes and states I am an authorized
representative of BIZFUND LLC in the within action. I have read the foregoing Verified
Complaint and know the contents thereof, the same is true to my knowledge, except as to the
matters therein stated to be alleged upon information and belief and as to those matters I believe
them to be true
The foregoing statements are under the penalty of perjury
Sworn to before me this
MARCH 26, 2024
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/26/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
------------------------------------------------------------------x
BIZFUND LLC
Plaintiff,
-against-
ADEPT SALES SOLUTIONS & CONSULTING LLC DBA ALL AMERICAN PROMOTIONS &
MARKETING AND JCW ENTERPRISES
AND JAMES CLYDE WILSON JR
Defendants.
------------------------------------------------------------------x
NOTICE OF ELECTRONIC FILING
(Mandatory Case)
(Uniform Rule § 202.5-bb)
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
9 of 10
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NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/26/2024
contact information can be found at www.nycourts.gov
To find legal information to help you represent yourself visit http://www.nycourthelp.gov/
Information for Attorneys
(E-filing is Mandatory for Attorneys)
An attorney representing a party who is served with this notice must either:
1) immediately record his or her representation within the e-filed matter on the
NYSCEF site ; or
2) file the Notice of Opt-Out form with the clerk of the court where this action is
pending and serve on all parties. Exemptions from mandatory e-filing are limited to
attorneys who certify in good faith that they lack the computer hardware and/or
scanner and/or internet connection or that they lack (along with all employees subject
to their direction) the knowledge to operate such equipment. [Section 202.5-bb(e)]
For additional information about electronic filing and to create a NYSCEF account, visit the
NYSCEF website at or contact the NYSCEF Resource Center
(phone: 646-386-3033; e-mail: nyscef@nycourts.gov).
Dated: Brooklyn, New York
MARCH 26, 2024
SCHECHTER LAW OFFICE, PLLC
By: _______Brian Schechter_____________________
Brian Schechter, Esq.
Attorneys for Plaintiff
315 Avenue U
Brooklyn, New York 11223
T: (302) 342-8810
F: (212) 735-1422
Brian@schechterlegal.com
TO: DEFENDANTS LISTED ON THE SUMMONS
10 of 10
Preview
FILED: KINGS COUNTY CLERK 03/26/2024 12:16 PM INDEX NO. 508565/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/26/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS -------------------------------------------------------------------X Index No. BIZFUND LLC Date Filed: Plaintiff, SUMMONS -against- Plaintiff’s place of business: 315 AVENUE U BROOKLYN NY 11223 ADEPT SALES SOLUTIONS & CONSULTING LLC DBA ALL AMERICAN PROMOTIONS & MARKETING AND JCW ENTERPRISES, AND JAMES CLYDE WILSON JR Defendants. Basis of venue and place of trial set at KINGS County: Pursuant to the agreement -------------------------------------------------------------------X To the above-named defendants: YOU ARE HERBY SUMMONED to answer the complaint in this action and to serve a copy of your answer, or, if the complaint is not served with the summons, to serve a notice of appearance, on the plaintiff’s attorney within 20 days after the service of this summons, exclusive of the day of service (or within 30 days after the service is complete if this summons is not personally delivered to you within the State of New York); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. SCHECHTER LAW OFFICE, PLLC Dated: Brooklyn, New York MARCH 26, 2024 By: _____Brian Schechter________________________ Brian Schechter, Esq. Attorneys for Plaintiff 315 Avenue U Brooklyn, New York 11223 T: (302) 342-8810 Brian@schechterlegal.com ADEPT SALES SOLUTIONS & CONSULTING LLC DBA ALL AMERICAN PROMOTIONS & MARKETING 550 S Watters St STE 131, Allen, Texas, 75013 JCW ENTERPRISES 550 S Watters St STE 131, Allen, Texas, 75013 1 of 10 FILED: KINGS COUNTY CLERK 03/26/2024 12:16 PM INDEX NO. 508565/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/26/2024 JAMES CLYDE WILSON JR 3310 Timberview Rd, Dallas, Texas,75229 2 of 10 FILED: KINGS COUNTY CLERK 03/26/2024 12:16 PM INDEX NO. 508565/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/26/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS -------------------------------------------------------------------X BIZFUND LLC VERIFIEDCOMPLAINT Plaintiff, -against- ADEPT SALES SOLUTIONS & CONSULTING LLC DBA ALL AMERICAN PROMOTIONS & MARKETING AND JCW ENTERPRISES AND JAMES CLYDE WILSON JR Defendants. -------------------------------------------------------------------X Plaintiff, BIZFUND LLC, by its attorney, Schechter Law Office PLLC, complaining of the Defendants ADEPT SALES SOLUTIONS & CONSULTING LLC DBA ALL AMERICAN PROMOTIONS & MARKETING AND JCW ENTERPRISES AND JAMES CLYDE WILSON JR, alleges as follows: PARTIES 1. Plaintiff, BIZFUND LLC (hereinafter referred to as (“PURCHASER” or “Plaintiff”) with its principal place of business at 315 AVENUE U BROOKLYN NY 11223 is a Delaware Limited Liability Company. 2. Upon information and belief, Defendant ADEPT SALES SOLUTIONS & CONSULTING LLC DBA ALL AMERICAN PROMOTIONS & MARKETING AND JCW ENTERPRISES (hereinafter referred to as “MERCHANT”) is/are a business organized and existing under the laws of TX located 550 S Watters St STE 131, Allen, Texas, 75013. 3. Defendant JAMES CLYDE WILSON JR (hereinafter referred to as “PERFORMANCE GUARANTOR(S)”) is/are a natural person and upon information and belief, at all times hereinafter mentioned, was and is a resident of the state of TX residing at 3310 3 of 10 FILED: KINGS COUNTY CLERK 03/26/2024 12:16 PM INDEX NO. 508565/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/26/2024 Timberview Rd, Dallas, Texas,75229. (MERCHANT and PERFORMANCE GUARANTOR(S) are hereinafter individually referred to as “Defendant” and collectively referred to as “Defendants”). 4. Defendants have consented to the jurisdiction of this Court pursuant to the Agreement referenced below. AS AND FOR A FIRST CAUSE OF ACTION AGAINST DEFENDANT MERCHANT 5. Plaintiff repeats and realleges the allegations contained in paragraphs “1” through “4” above as though fully set forth herein at length. 6. On or about NOVEMBER 2, 2023, PURCHASER entered into a Sales Agreement(s) with MERCHANT (the “Agreement”) wherein and whereby for the sum of $45,000.00, at the special instance and request of MERCHANT, PURCHASER agreed to buy and MERCHANT agreed to sell the future receivables of MERCHANT in the sum of $65,250.00 to be paid by MERCHANT as an estimated weekly payment of $2,999.00 OR a daily payment of $600 pursuant to the Agreement until paid in full. A true copy of the Agreement is annexed hereto as Exhibit A. 7. During the course of the Agreement, the unpaid sums become due and payable in full as required by the Plaintiff or pursuant to the terms of the Agreement on the happening of any event of default or the breach of any covenants or warranties prescribed under the Agreement. 8. MERCHANT defaulted under the terms of the Agreement by breaching its representations and warranties. Additionally, MERCHANT has refused to make all payments due under the Agreement despite due demand, therefore. All sums due at default become immediately due and payable. 4 of 10 FILED: KINGS COUNTY CLERK 03/26/2024 12:16 PM INDEX NO. 508565/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/26/2024 9. After all payments, credits, offsets, and deductions, under the Agreement there is a balance plus contractual fees as of this date in the sum of $44,357.00 10. No payment has been made since MARCH 18, 2024, leaving a balance in the sum of $44,357.00 plus interest at the statutory rate from MARCH 18, 2024. 11. MERCHANT is currently in default under the terms of the Agreement so that the balance in the sum of $44,357.00 plus statutory interest from MARCH 18, 2024, is now due and owing to plaintiff. 12. By reason of the foregoing, MERCHANT is liable to PURCHASER in the sum $44,357.00 plus interest at the statutory rate from MARCH 18, 2024, through the entry of judgment herein. AS AND FOR A SECOND CAUSE OF ACTION AGAINST DEFENDANT PERFORMANCE GUARANTOR(S)(S) 13. Plaintiff repeats and realleges the allegations contained in paragraphs “1” through “12” above as though fully set forth herein at length. 14. In connection with the Agreement, PERFORMANCE GUARANTOR(S)(S) made and delivered to PURCHASER a written personal guarantee of MERCHANT performance under the Agreement. Said guarantee states: “The undersigned Guarantor(s) hereby irrevocably and unconditionally guarantees to Purchaser Merchant’s Performance when due. . .” A true copy of the guarantee is annexed in Exhibit A. 15. Defendant MERCHANT failed to perform under the terms and conditions of the Agreement, rendering Defendant PERFORMANCE GUARANTOR(S)(S) personally liable pursuant to the terms of the guarantee. 5 of 10 FILED: KINGS COUNTY CLERK 03/26/2024 12:16 PM INDEX NO. 508565/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/26/2024 16. Defendant PERFORMANCE GUARANTOR(S)(S) is currently in default under the terms of the Agreement so that the balance in the sum of $44,357.00 plus statutory interest from MARCH 18, 2024, is now due and owing to plaintiff. 17. By reason of the foregoing, Defendant PERFORMANCE GUARANTOR(S)(S) is liable to PURCHASER in the sum $44,357.00 plus interest at the statutory rate from MARCH 18, 2024, through the entry of judgment herein. AS AND FOR A THIRD CAUSE OF ACTION AGAINST ALL DEFENDANTS 18. Plaintiff repeats and realleges the allegations contained in paragraphs “1” through “17” above as though fully set forth herein at length. 19. The Agreement provides that in addition to all payments owed under the Agreement, MERCHANT agrees to pay all costs associated with a breach . . . and the enforcement thereof, including but not limited to court costs and attorneys’ fees and disbursements. 20. The guarantee of Defendant PERFORMANCE GUARANTOR(S)(S) provides that the guarantor shall pay costs, expenses and attorneys’ fees which may be incurred as a result of the Guarantor’s default under the guarantee. 21. Plaintiff has incurred and continues to incur expenses including attorneys’ fees, which cannot be finally determined at this date, but which will be capable of determination at such time as judgment may be entered herein. 22. By reason of the foregoing, Defendants MERCHANT and PERFORMANCE GUARANTOR(S)(S) are liable to Plaintiff for Plaintiff’s expenses in regard to this litigation, including attorneys’ fees, in such amount as may be determined. WHEREFORE, Plaintiff demands judgment: 6 of 10 FILED: KINGS COUNTY CLERK 03/26/2024 12:16 PM INDEX NO. 508565/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/26/2024 a. on the first cause of action against Defendant MERCHANT in the sum of $44,357.00 plus interest at the statutory rate from MARCH 18, 2024, through the entry of judgment herein; b. on the second cause of action against Defendant PERFORMANCE GUARANTOR(S) in the sum of $44,357.00 plus interest at the statutory rate from MARCH 18, 2024, through the entry of judgment herein; c. on the third cause of action against Defendants MERCHANT and PERFORMANCE GUARANTOR(S)(S), jointly and severally awarding Plaintiff attorneys fees together with costs and expenses incurred in prosecuting this action in an amount to be determined by the Court. Dated: Brooklyn, New York MARCH 26, 2024 SCHECHTER LAW OFFICE, PLLC By: _______Brian Schechter_____________________ Brian Schechter, Esq. Attorneys for Plaintiff 315 Avenue U Brooklyn, New York 11223 T: (302) 342-8810 F: (212) 735-1422 Brian@schechterlegal.com 7 of 10 FILED: KINGS COUNTY CLERK 03/26/2024 12:16 PM INDEX NO. 508565/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/26/2024 VFERIFICATION STATE OF NEW YORK ) ) ss: COUNTY OF KINGS ) RAYMOND MIZRAHI , being duly sworn deposes and states I am an authorized representative of BIZFUND LLC in the within action. I have read the foregoing Verified Complaint and know the contents thereof, the same is true to my knowledge, except as to the matters therein stated to be alleged upon information and belief and as to those matters I believe them to be true The foregoing statements are under the penalty of perjury Sworn to before me this MARCH 26, 2024 8 of 10 FILED: KINGS COUNTY CLERK 03/26/2024 12:16 PM INDEX NO. 508565/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/26/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ------------------------------------------------------------------x BIZFUND LLC Plaintiff, -against- ADEPT SALES SOLUTIONS & CONSULTING LLC DBA ALL AMERICAN PROMOTIONS & MARKETING AND JCW ENTERPRISES AND JAMES CLYDE WILSON JR Defendants. ------------------------------------------------------------------x NOTICE OF ELECTRONIC FILING (Mandatory Case) (Uniform Rule § 202.5-bb) 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 9 of 10 FILED: KINGS COUNTY CLERK 03/26/2024 12:16 PM INDEX NO. 508565/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/26/2024 contact information can be found at www.nycourts.gov To find legal information to help you represent yourself visit http://www.nycourthelp.gov/ Information for Attorneys (E-filing is Mandatory for Attorneys) An attorney representing a party who is served with this notice must either: 1) immediately record his or her representation within the e-filed matter on the NYSCEF site ; or 2) file the Notice of Opt-Out form with the clerk of the court where this action is pending and serve on all parties. Exemptions from mandatory e-filing are limited to attorneys who certify in good faith that they lack the computer hardware and/or scanner and/or internet connection or that they lack (along with all employees subject to their direction) the knowledge to operate such equipment. [Section 202.5-bb(e)] For additional information about electronic filing and to create a NYSCEF account, visit the NYSCEF website at or contact the NYSCEF Resource Center (phone: 646-386-3033; e-mail: nyscef@nycourts.gov). Dated: Brooklyn, New York MARCH 26, 2024 SCHECHTER LAW OFFICE, PLLC By: _______Brian Schechter_____________________ Brian Schechter, Esq. Attorneys for Plaintiff 315 Avenue U Brooklyn, New York 11223 T: (302) 342-8810 F: (212) 735-1422 Brian@schechterlegal.com TO: DEFENDANTS LISTED ON THE SUMMONS 10 of 10