Preview
FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM INDEX NO. E2024007188
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024
MONROE COUNTY CLERK’S OFFICE THIS IS NOT A BILL. THIS IS YOUR RECEIPT.
Receipt # 3845858
Book Page CIVIL
Return To: No. Pages: 19
SCOTT ANDREW MORRIS
39 BROADWAY RM 1250 Instrument: EFILING INDEX NUMBER
NEW YORK, NY 10006-3089
Control #: 202404300129
Index #: E2024007188
Date: 04/30/2024
CROWN ASSET MANAGEMENT LLC Time: 9:09:36 AM
Karaibrahim, Binhan
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 19
202404300129 04/30/2024 09:09:36 AM CIVIL
202404300129
INDEX NO. E2024007188
FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024
CONSUMER CREDIT TRANSACTION
Date Purchased:
SUPREME COURT OF THE STATE OF NEW YORK Index №
COUNTY OF MONROE X
Crown Asset Management, LLC SUMMONS
Plaintiff, Plaintiff's Address:
-against- 3100 Breckinridge Blvd. Suite 725
Duluth GA 30096
Binhan Karaibrahim
Defendant(s).
The Basis of Venue is:
CPLR SEC. 503(f). Defendants
residence is in the County of
MONROE.
X
Defendant(s) Address:
DEF1- 297 ANNIE LANE, ROCHESTER NY 14626
TO THE ABOVE NAMED DEFENDANT(S):
YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a copy of your
answer on the Plaintiff's Attorney(s) within 20 days after the service of this summons, exclusive of the day of
service, or within 30 days after service is complete if this summons is not personally delivered to you within the
State of New York; and in the case of your failure to appear or answer, judgment will be taken against you by
default for the relief demanded in the complaint.
We are attorneys attempting to collect a debt. Any information obtained will be used for that purpose.
Dated: April 23, 2024
Matter # 510774 ____________________________
Stephen Einstein Scott Morris
Anthony S. Poulin Dianne Ramdeen
Sharil Clarke Joseph G. Devine
Chester Andrew Guala Richa Bhandari
Tromberg, Morris & Poulin, PLLC.
Attorneys for the Plaintiff
39 Broadway, Suite 1250
New York, N.Y. 10006
(212) 267-3550
*SM0000510774*
S_S_SUP-SUM
2 of 19
202404300129 04/30/2024 09:09:36 AM CIVIL
202404300129
INDEX NO. E2024007188
FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024
SUPREME COURT OF THE STATE OF NEW YORK INDEX №:
COUNTY OF MONROE
Crown Asset Management, LLC
Plaintiff,
-against-
COMPLAINT
Binhan Karaibrahim
Defendant(s).
Plaintiff, by its undersigned attorneys, complaining of the Defendant(s), respectfully alleges that:
FIRST: Plaintiff is an active foreign entity conducting business in the state of GA. Upon information
and belief, at all times hereinafter mentioned, Defendant(s) resides in the county in which this action is
brought, or transacted business in person or through an agent within the county in which this action is
brought and the instant cause of action arose out of said transaction.
SECOND: Based upon a reasonable inquiry, the Statute of Limitations for the cause of action asserted
herein has not expired.
THIRD: That the Defendant(s) entered into a non-revolving credit agreement (hereinafter
ee en Cross River Bank, the Original Creditor as defined by CPLR §105(q-1), bearing an
account number ending in XXXX9540, promising to repay all amounts financed plus interest. A copy of
the Agreement is attached hereto.
FOURTH: Defendant(s) defaulted in payment and pursuant to the terms of the Agreement now
owes a balance of $3,590.96 as of 4/26/2023, no part of which has been paid despite due demand; a complete
transaction history itemizing any (i) principal; (ii) finance charge or charges; (iii) fees imposed by the
original creditor; (iv) collection costs; (v) attorney's fees; (vi) interest; and (vii) any other fees and charges;
less post-sale credits or payments made by or on behalf of the Defendant, is attached hereto.
FIFTH: Subsequently, the Original Creditor sold/ assigned the Agreement, where Plaintiff, purchased
and/or took assignment of the account herein.The complete chain of sale and assignment and dates sold and/or
assigned are as follows:
Assignor Date of Transfer Amt. at Time of Transfer
Transfer 1: Cross River Bank 05/26/2023 $3,590.96
SIXTH: Upon information and belief the date of last payment on this account was 12/12/2022 in
the amount of $121.62.
WHEREFORE, Plaintiff demands judgment against the Defendant(s) in the sum of $3,590.96 with
interest from 4/26/2023 together with the costs and disbursements of this action.
CERTIFICATION: Deponent is an attorney associated with Tromberg, Morris & Poulin, PLLC. Deponent
certifies that, to the best of their knowledge, information and belief, formed after an inquiry reasonable
under the circumstances, the presentation of the paper or the contentions therein are not frivolous as defined
in section 130-1.1(c) of the Chief Administrative Judge, and an initiating pleading, the matter was not
obtained through illegal conduct, and the matter was not obtained in violation of Part 1200. Rule 4.5 of this
Title. Affirmed this 23rd day of April, 2024.
S_S_COM-BAN3
3 of 19
202404300129 04/30/2024 09:09:36 AM CIVIL
202404300129
INDEX NO. E2024007188
FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024
____________________________
Stephen Einstein Scott Morris
Anthony S. Poulin Dianne Ramdeen
Sharil Clarke Joseph G. Devine
Chester Andrew Guala Richa Bhandari
Matter # 510774
S_S_COM-BAN3
4 of 19
202404300129 04/30/2024 09:09:36 AM CIVIL
202404300129
INDEX NO. E2024007188
FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024
EXHIBITS
(Agreement/Contract)
(Transaction History)
S_S_COM-BAN3
5 of 19
202404300129 04/30/2024 09:09:36 AM CIVIL
202404300129
INDEX NO. E2024007188
FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024
6 of 19
202404300129 04/30/2024 09:09:36 AM CIVIL
202404300129
INDEX NO. E2024007188
FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024
7 of 19
202404300129 04/30/2024 09:09:36 AM CIVIL
202404300129
INDEX NO. E2024007188
FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024
8 of 19
202404300129 04/30/2024 09:09:36 AM CIVIL
202404300129
INDEX NO. E2024007188
FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024
9 of 19
202404300129 04/30/2024 09:09:36 AM CIVIL
202404300129
INDEX NO. E2024007188
FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024
10 of 19
202404300129 04/30/2024 09:09:36 AM CIVIL
202404300129
INDEX NO. E2024007188
FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024
11 of 19
202404300129 04/30/2024 09:09:36 AM CIVIL
202404300129
INDEX NO. E2024007188
FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024
12 of 19
202404300129 04/30/2024 09:09:36 AM CIVIL
202404300129
INDEX NO. E2024007188
FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024
13 of 19
202404300129 04/30/2024 09:09:36 AM CIVIL
202404300129
INDEX NO. E2024007188
FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024
14 of 19
202404300129 04/30/2024 09:09:36 AM CIVIL
202404300129
INDEX NO. E2024007188
FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024
15 of 19
202404300129 04/30/2024 09:09:36 AM CIVIL
202404300129
INDEX NO. E2024007188
FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024
16 of 19
202404300129 04/30/2024 09:09:36 AM CIVIL
202404300129
INDEX NO. E2024007188
FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM
NYSCEF DOC. NO. 1 Index No. Year RECEIVED NYSCEF: 04/29/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF MONROE
Crown Asset Management, LLC
Plaintiff
-against-
Binhan Karaibrahim
Defendant(s)
SUMMONS AND COMPLAINT
Signature (Rule 130-1. 1-a)
____________________________
Stephen Einstein Scott Morris
Anthony S. Poulin Dianne Ramdeen
Sharil Clarke Joseph G. Devine
Chester Andrew Guala Richa Bhandari
LAW OFFICE OF
TROMBERG, MORRIS & POULIN, PLLC.
Attorney(s) for Plaintiff
Office and Post Office Address
39 Broadway, Suite 1250
New York, New York 10006
(212) 267-3550
Fax (212) 227-9656
Service of a copy of the within ___________________ is hereby admitted.
Dated,
Attorney(s) for Plaintiff(s)
Sir: Please take notice
NOTICE OF ENTRY:
That within is a (certified) true copy of a duly entered in the office of the clerk
of the within named court on
NOTICE OF SETTLEMENT
That an order __________________ of which the within is a true copy of a
Settlement to the HON. ___________________ Presented for one of the
judges
Of the within named court, at
On the ___ day of _____ 2024 at __ A.M
Dated,
S_S_SUP-BB
17 of 19
202404300129 04/30/2024 09:09:36 AM CIVIL
202404300129
INDEX NO. E2024007188
FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024
SUPREME COURT OF THE STATE OF NEW YORK INDEX №:
COUNTY OF MONROE
Crown Asset Management, LLC
Plaintiff,
-against-
Binhan Karaibrahim
Defendant(s).
NOTICE OF COMMENCEMENT OF ACTION
SUBJECT TO MANDATORY ELECTRONIC FILING
PLEASE TAKE NOTICE that the matter captioned above has been commenced as an
electronically filed case in the New York State Courts Electronic Filing System (“NYSCEF”) as
required by CPLR § 2111 and Uniform Rule § 202.5-bb (MANDATORY ELECTRONIC FILING).
This notice is being served as required by that rule.
NYSCEF is designed for the electronic filing of documents with the County Clerk and the
court and for the electronic service of those documents, court documents, and court notices upon
counsel and unrepresented litigants who have consented to electronic filing.
Electronic filing offers significant benefits for attorneys and litigants, permitting papers to be
filed with the County Clerk and the court and served on other parties simply, conveniently, and
quickly. NYSCEF case documents are filed with the County Clerk and the court by filing on the
NYSCEF Website, which can be done at any time of the day or night on any day of the week. The
documents are served automatically on all consenting e-filers as soon as the document is uploaded to
the website, which sends out an immediate email notification of the filing.
The NYSCEF System charges no fees for filing, serving, or viewing the electronic case record,
nor does it charge any fees to print any filed documents. Normal filing fees must be paid, but this can
be done on-line.
Parties represented by an attorney: 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. 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 operational knowledge to comply with e-filing
requirements. [Section 202.5-bb(e)]
Parties not represented by an attorney: Unrepresented litigants are exempt from efiling.
They can serve and file documents in paper form and must be served with documents in paper
form. However, an unrepresented litigant may participate in e-filing. For information on how to
participate in e-filing, unrepresented litigants should contact the appropriate clerk in the court where
the action was filed or visit www.nycourts.gov/efileunrepresented. Unrepresented litigants also are
encouraged to visit www.nycourthelp.gov or contact the Help Center in the court where the action
was filed. An unrepresented litigant who consents to e-filing may cease participation at any time.
However, the other parties may continue to e-file their court documents in the case.
S_S-EFI
18 of 19
202404300129 04/30/2024 09:09:36 AM CIVIL
202404300129
INDEX NO. E2024007188
FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024
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: April 23, 2024
____________________________
Stephen Einstein Scott Morris
Anthony S. Poulin Dianne Ramdeen
Sharil Clarke Joseph G. Devine
Chester Andrew Guala Richa Bhandari
Tromberg, Morris & Poulin, PLLC.
39 Broadway, Suite 1250
New York, N.Y. 10006
(212) 267-3550
www.tmppllc.com
TO: Binhan Karaibrahim
297 Annie Lane
Rochester NY 14626
Matter # 510774
S_S-EFI
19 of 19
Preview
FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM INDEX NO. E2024007188 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 MONROE COUNTY CLERK’S OFFICE THIS IS NOT A BILL. THIS IS YOUR RECEIPT. Receipt # 3845858 Book Page CIVIL Return To: No. Pages: 19 SCOTT ANDREW MORRIS 39 BROADWAY RM 1250 Instrument: EFILING INDEX NUMBER NEW YORK, NY 10006-3089 Control #: 202404300129 Index #: E2024007188 Date: 04/30/2024 CROWN ASSET MANAGEMENT LLC Time: 9:09:36 AM Karaibrahim, Binhan 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 19 202404300129 04/30/2024 09:09:36 AM CIVIL 202404300129 INDEX NO. E2024007188 FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 CONSUMER CREDIT TRANSACTION Date Purchased: SUPREME COURT OF THE STATE OF NEW YORK Index № COUNTY OF MONROE X Crown Asset Management, LLC SUMMONS Plaintiff, Plaintiff's Address: -against- 3100 Breckinridge Blvd. Suite 725 Duluth GA 30096 Binhan Karaibrahim Defendant(s). The Basis of Venue is: CPLR SEC. 503(f). Defendants residence is in the County of MONROE. X Defendant(s) Address: DEF1- 297 ANNIE LANE, ROCHESTER NY 14626 TO THE ABOVE NAMED DEFENDANT(S): YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a copy of your answer on the Plaintiff's Attorney(s) within 20 days after the service of this summons, exclusive of the day of service, or within 30 days after service is complete if this summons is not personally delivered to you within the State of New York; and in the case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. We are attorneys attempting to collect a debt. Any information obtained will be used for that purpose. Dated: April 23, 2024 Matter # 510774 ____________________________ Stephen Einstein Scott Morris Anthony S. Poulin Dianne Ramdeen Sharil Clarke Joseph G. Devine Chester Andrew Guala Richa Bhandari Tromberg, Morris & Poulin, PLLC. Attorneys for the Plaintiff 39 Broadway, Suite 1250 New York, N.Y. 10006 (212) 267-3550 *SM0000510774* S_S_SUP-SUM 2 of 19 202404300129 04/30/2024 09:09:36 AM CIVIL 202404300129 INDEX NO. E2024007188 FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 SUPREME COURT OF THE STATE OF NEW YORK INDEX №: COUNTY OF MONROE Crown Asset Management, LLC Plaintiff, -against- COMPLAINT Binhan Karaibrahim Defendant(s). Plaintiff, by its undersigned attorneys, complaining of the Defendant(s), respectfully alleges that: FIRST: Plaintiff is an active foreign entity conducting business in the state of GA. Upon information and belief, at all times hereinafter mentioned, Defendant(s) resides in the county in which this action is brought, or transacted business in person or through an agent within the county in which this action is brought and the instant cause of action arose out of said transaction. SECOND: Based upon a reasonable inquiry, the Statute of Limitations for the cause of action asserted herein has not expired. THIRD: That the Defendant(s) entered into a non-revolving credit agreement (hereinafter ee en Cross River Bank, the Original Creditor as defined by CPLR §105(q-1), bearing an account number ending in XXXX9540, promising to repay all amounts financed plus interest. A copy of the Agreement is attached hereto. FOURTH: Defendant(s) defaulted in payment and pursuant to the terms of the Agreement now owes a balance of $3,590.96 as of 4/26/2023, no part of which has been paid despite due demand; a complete transaction history itemizing any (i) principal; (ii) finance charge or charges; (iii) fees imposed by the original creditor; (iv) collection costs; (v) attorney's fees; (vi) interest; and (vii) any other fees and charges; less post-sale credits or payments made by or on behalf of the Defendant, is attached hereto. FIFTH: Subsequently, the Original Creditor sold/ assigned the Agreement, where Plaintiff, purchased and/or took assignment of the account herein.The complete chain of sale and assignment and dates sold and/or assigned are as follows: Assignor Date of Transfer Amt. at Time of Transfer Transfer 1: Cross River Bank 05/26/2023 $3,590.96 SIXTH: Upon information and belief the date of last payment on this account was 12/12/2022 in the amount of $121.62. WHEREFORE, Plaintiff demands judgment against the Defendant(s) in the sum of $3,590.96 with interest from 4/26/2023 together with the costs and disbursements of this action. CERTIFICATION: Deponent is an attorney associated with Tromberg, Morris & Poulin, PLLC. Deponent certifies that, to the best of their knowledge, information and belief, formed after an inquiry reasonable under the circumstances, the presentation of the paper or the contentions therein are not frivolous as defined in section 130-1.1(c) of the Chief Administrative Judge, and an initiating pleading, the matter was not obtained through illegal conduct, and the matter was not obtained in violation of Part 1200. Rule 4.5 of this Title. Affirmed this 23rd day of April, 2024. S_S_COM-BAN3 3 of 19 202404300129 04/30/2024 09:09:36 AM CIVIL 202404300129 INDEX NO. E2024007188 FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 ____________________________ Stephen Einstein Scott Morris Anthony S. Poulin Dianne Ramdeen Sharil Clarke Joseph G. Devine Chester Andrew Guala Richa Bhandari Matter # 510774 S_S_COM-BAN3 4 of 19 202404300129 04/30/2024 09:09:36 AM CIVIL 202404300129 INDEX NO. E2024007188 FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 EXHIBITS (Agreement/Contract) (Transaction History) S_S_COM-BAN3 5 of 19 202404300129 04/30/2024 09:09:36 AM CIVIL 202404300129 INDEX NO. E2024007188 FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 6 of 19 202404300129 04/30/2024 09:09:36 AM CIVIL 202404300129 INDEX NO. E2024007188 FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 7 of 19 202404300129 04/30/2024 09:09:36 AM CIVIL 202404300129 INDEX NO. E2024007188 FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 8 of 19 202404300129 04/30/2024 09:09:36 AM CIVIL 202404300129 INDEX NO. E2024007188 FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 9 of 19 202404300129 04/30/2024 09:09:36 AM CIVIL 202404300129 INDEX NO. E2024007188 FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 10 of 19 202404300129 04/30/2024 09:09:36 AM CIVIL 202404300129 INDEX NO. E2024007188 FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 11 of 19 202404300129 04/30/2024 09:09:36 AM CIVIL 202404300129 INDEX NO. E2024007188 FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 12 of 19 202404300129 04/30/2024 09:09:36 AM CIVIL 202404300129 INDEX NO. E2024007188 FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 13 of 19 202404300129 04/30/2024 09:09:36 AM CIVIL 202404300129 INDEX NO. E2024007188 FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 14 of 19 202404300129 04/30/2024 09:09:36 AM CIVIL 202404300129 INDEX NO. E2024007188 FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 15 of 19 202404300129 04/30/2024 09:09:36 AM CIVIL 202404300129 INDEX NO. E2024007188 FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 16 of 19 202404300129 04/30/2024 09:09:36 AM CIVIL 202404300129 INDEX NO. E2024007188 FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM NYSCEF DOC. NO. 1 Index No. Year RECEIVED NYSCEF: 04/29/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF MONROE Crown Asset Management, LLC Plaintiff -against- Binhan Karaibrahim Defendant(s) SUMMONS AND COMPLAINT Signature (Rule 130-1. 1-a) ____________________________ Stephen Einstein Scott Morris Anthony S. Poulin Dianne Ramdeen Sharil Clarke Joseph G. Devine Chester Andrew Guala Richa Bhandari LAW OFFICE OF TROMBERG, MORRIS & POULIN, PLLC. Attorney(s) for Plaintiff Office and Post Office Address 39 Broadway, Suite 1250 New York, New York 10006 (212) 267-3550 Fax (212) 227-9656 Service of a copy of the within ___________________ is hereby admitted. Dated, Attorney(s) for Plaintiff(s) Sir: Please take notice NOTICE OF ENTRY: That within is a (certified) true copy of a duly entered in the office of the clerk of the within named court on NOTICE OF SETTLEMENT That an order __________________ of which the within is a true copy of a Settlement to the HON. ___________________ Presented for one of the judges Of the within named court, at On the ___ day of _____ 2024 at __ A.M Dated, S_S_SUP-BB 17 of 19 202404300129 04/30/2024 09:09:36 AM CIVIL 202404300129 INDEX NO. E2024007188 FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 SUPREME COURT OF THE STATE OF NEW YORK INDEX №: COUNTY OF MONROE Crown Asset Management, LLC Plaintiff, -against- Binhan Karaibrahim Defendant(s). NOTICE OF COMMENCEMENT OF ACTION SUBJECT TO MANDATORY ELECTRONIC FILING PLEASE TAKE NOTICE that the matter captioned above has been commenced as an electronically filed case in the New York State Courts Electronic Filing System (“NYSCEF”) as required by CPLR § 2111 and Uniform Rule § 202.5-bb (MANDATORY ELECTRONIC FILING). This notice is being served as required by that rule. NYSCEF is designed for the electronic filing of documents with the County Clerk and the court and for the electronic service of those documents, court documents, and court notices upon counsel and unrepresented litigants who have consented to electronic filing. Electronic filing offers significant benefits for attorneys and litigants, permitting papers to be filed with the County Clerk and the court and served on other parties simply, conveniently, and quickly. NYSCEF case documents are filed with the County Clerk and the court by filing on the NYSCEF Website, which can be done at any time of the day or night on any day of the week. The documents are served automatically on all consenting e-filers as soon as the document is uploaded to the website, which sends out an immediate email notification of the filing. The NYSCEF System charges no fees for filing, serving, or viewing the electronic case record, nor does it charge any fees to print any filed documents. Normal filing fees must be paid, but this can be done on-line. Parties represented by an attorney: 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. 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 operational knowledge to comply with e-filing requirements. [Section 202.5-bb(e)] Parties not represented by an attorney: Unrepresented litigants are exempt from efiling. They can serve and file documents in paper form and must be served with documents in paper form. However, an unrepresented litigant may participate in e-filing. For information on how to participate in e-filing, unrepresented litigants should contact the appropriate clerk in the court where the action was filed or visit www.nycourts.gov/efileunrepresented. Unrepresented litigants also are encouraged to visit www.nycourthelp.gov or contact the Help Center in the court where the action was filed. An unrepresented litigant who consents to e-filing may cease participation at any time. However, the other parties may continue to e-file their court documents in the case. S_S-EFI 18 of 19 202404300129 04/30/2024 09:09:36 AM CIVIL 202404300129 INDEX NO. E2024007188 FILED: MONROE COUNTY CLERK 04/29/2024 10:29 PM NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 04/29/2024 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: April 23, 2024 ____________________________ Stephen Einstein Scott Morris Anthony S. Poulin Dianne Ramdeen Sharil Clarke Joseph G. Devine Chester Andrew Guala Richa Bhandari Tromberg, Morris & Poulin, PLLC. 39 Broadway, Suite 1250 New York, N.Y. 10006 (212) 267-3550 www.tmppllc.com TO: Binhan Karaibrahim 297 Annie Lane Rochester NY 14626 Matter # 510774 S_S-EFI 19 of 19