Preview
FILED: SUFFOLK COUNTY CLERK 06/14/2024 02:33 PM INDEX NO. 614693/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/14/2024
SUPREMECOURTOFTHESTATEOFNEWYORK Index No.:
COUNTYOFSUFFOLK Date Summonsfiled:
-------------------------------------------------------------X Plaintiffdesignates SUFFOLK
County as the place of trial
Oona Haaranen-Schorr, as Attorney in Fact for Seymour Schort The basis ofvenue is:
Plaintiff,
-against- SUMMONS
Plaintif/Defendant resides at:
Oons & Seymour Schorr
54180 Main Road, Unit A
Lieb at Law, P.C· Defendant. Southold, NY 11971
To the above named Defendant:
YOUAREHEREBY SUMMONED to answer the complaint in this action and to serve
a copy of your answer on the O Plaintif ORQ Plaintiff's twenty (20) days
Attorney(s) within
after the service of this summons,exclusive ofthe day of service, where service is made by delivery
upon you personally within the state, or within thirty (30) days after completion of service where
service is made in any other manner. In case of your failure to appear or answer, judgment will be
taken against you by default for the relief demanded in the complaint.
Dated
June 14, 2024 O Plaintif
Q Attorney(s) for Plaintiff
Address:
5q 96 / t½ ain Ñon t)
,
Ori
Phone No.: 917-859-6699
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SUPREMECOURTOFTHESTATEOF NEWYORK
COUNTYOFSUFFOLK
--------------------------x
OonaHaaranen-Schorr, as Attorney in Fact for Seymour Schorr
Plaintiffs, Index No. /20__
- against- COMPLAINT
Lieb at Law, P.C.
Defendant
________-----_____ _ _ _ ______Ç
COURTOFTHE STATEOFNEW
THESUPREME YORK
The complaint of the plaintiffs, OonaHaaranen-Schorr and Seymour Schorr respectfully shows and
alledges as follows:
1. Plaintiffs, OonaHaaranen-Schort, as Attorney in Fact forSeymour Schort, is a resident of State of New
York. Oonaand Seymour Schorr reside at 24180 Main Road, Unit A, Southold, NewYork 11971.
2. The defendant herein Lieb at Law, P.C., has a principal place of business at 308 W. Main Street, Suite
100, Smithtown, NewYork 11787. Defendant is engaged in business of providing legal services.
plaintiffs'
3. Plaintiffs Schorr desired to have a fair pay out proposal, which would take into consideration
ownership interests in entities ownedin conjunction with Mr. Schort, his daughters and other related parties.
Plaintiffs'
and defendant (Andrew Lieb, Managing Partner) discussed specifications for this proceeding and how to
plaintiffs'
best obtain necessary information quickly taking into consideration age (90/92), 24/7 care requirements
Plaintiffs'
and limited funds. recurring monthly payments, from Mr. Schorr's other relatives as his business partners,
had been abruptly discontinued in September 2020, nine months prior to a very questionable payout offer from these
business partners/relatives.
4. July 13th, 2021 plaintiffs signed a retainer agreement with Lieb at Law P.C. for accounting proceeding.
Plaintiffs paid defendant the mtainer fee of $7500.
5. About three months later, on October 12th, 2021 the action was commencedwhendefendant Lieb Law
plaintiffs'
P.C. (Vasilios (Billy) Skulikidis, hereafter Att.#1) filed a Verified Summonsand Complaint, in original
case (index No: 619186/21).
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6. About 2.5 months later, on January 7th, Att.#1 provided plaintiff with a copy of the first discovery
demands and requested plaintiff to create a list of specific demands to add to the demand document. Plaintiff had last
communication with Att#1 February 4th, 2022.
7. About February 22nd, 2022 plaintiff makes several attempts to connect with the Att #1 in order to
provide him with the promised list and documents, but cannot locate him. Instead the defendant's secretary, Suzanne
plaintiffs'
Damante, starts to accept documents.
8. Approximately three months later, in April 2022, plaintiffs finds out that, Att. #1 had left the defendant's
law firm permanently, but nobody from the defendant's firm bothered to inform the plaintiff about this.
9. Around the end of April, 2022, defendant's secretary Suzanne Demante confirmed that another
plaintiffs'
supervisor/Lieb at Law P.C. partner, Mordy Yankovitch, (hereafter Att #2) was looking after case.
plaintiffs'
10. Nothing in case was moving forward, until the defendant was assigned to another attorney,
John Scherer (hereafter Att #3), who contacted the plaintiff on August 12th, 2022 and who continued reworking the
same demanddocuments provided to plainti ffs by their Att #1 in January 7th, 2022, eight months previously.
Plaintiffs were charged twice for these same demanddocuments (first time in December 2021 by Att #1), the
discovery demands, which were finally submitted to the defendant in plaintiffs original case in August 25, 2022 (and
charged for the second time in August 2022 ) with additional pages added by Att #3.
11. On December 21, 2022, one and half years later since signing the agreement with defendant's law
firm, plaintiffs finally received 400 pages of a discovery document dump (unorganized response without indications
Plaintiffs'
what each document referred and responded to) for the 8 (eight) businesses in the plaintiff's original case.
plaintiffs' defendants'
Att #3 requested an organized response from the original case attorney, which they promised
to provide.
defendants'
12. OnJanuary 3, 2023, the attorney (in the original law case) provided these organized
documents to defendant, Lieb Law P.C, who failed to produce and provide these documents to plaintiffs, even when
the plaintiffs were charged for filing these documents on that very day.
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13. OnJanuary 18, 2023 plaintiffs received an e-mail regarding ADRfrom a fourth attorney, Cheryl Berger,
(hereafter Att # 4) who the plaintiffs were not familiar with.
14. Since January 26, 2023, the plaintiffs sent several email requests to the defendants Att's #2, #3 and #4
as well as to secretary Suzanne Damante in order to receive the promised organized discovery responses and also to
inquire if the discovery responses contained enough information to moveto ADRor litigation. The plaintiffs also
inquired if their previous attorney, Att #3, had left Lieb at law P.C. because he was unreachable by the plaintiffs.
15. The Plaintiffs received no answers to these and to their other specific questions posed to the defendant.
Instead the defendant responded with answers to questions that were not asked by the plaintiffs, along with
distortions and falsifications, claiming that the defendant had answered already these questions by plaintiffs, which
they actually had not answered at all.
16. Because the plaintiffs did not receive professional guidance from the defendant, the plaintiffs could not
makean informed decision regarding ADRor litigation neither did plaintiffs know what was being done with their
case.
17. The plaintiffs, on their own accord, without any notice from the defendant, learned from the internet
about the scheduled MSTeams conference concerning the
plaintiffs'
own case, with the Judge on March 30, 2023,
attorneys'
and that clients also are actually allowed to attend such conferences. The defendant had failed to inform
plaintiffs about any of this.
18. At this Judge's conference, the plaintiff found out, from the defendants', Att # 4 and from yet another
new attorney to plaintiffs, Natalie Donaldson (hereafter Att # 5), the reasons for the defendant's delays with the
plaintiffs' Plaintiffs'
case. Att # 3 had indeed left the defendant's law firm in January 2023 without informing
plaintiffs. The other reasons for delays were stated by Att#5 at the meeting with the judge as: plaintiff's language
plaintiffs'
barrier, the need for communication to be in writing (which had not been an issue for Att#1 and Att #3),
plaintiffs'
and that newly appointed attorney at defendant's firm, Att #4, was busy with another case and so unable
to attend the judge meeting and that defendant (Att #4) now required yet more time to review the discovery
responses received in January 3, 2023.
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19. The defendant blamed the plaintiff's language barrier as the main cause for the delays in the case, when
in actuality there had been several changes in
plaintiffs'
representation in attorneys, each mquiring momtime to
learn the case and get up to speed; and piling up costs for the plaintiffs to pay. Plaintiff ended up being charged over
and over again for the same services paid for already previously, just because the persons (attorneys), handling and
familiarizing themselves with the case, kept on changing.
20. Defendant failed to inform plaintiffs about the constant changes in attorneys. Plaintiffs were left in the
dark, always surprised to be thrown to an unfamiliar person, next new attorney. Defendant did not inform and tried
to hide the fact, that their two previous attorney (Att #1 and Att #3) had left the company. It was months later that
the plaintiffs finally figured out the fact, that both of these attorneys had left the defendant's firm for good.
21. Plaintiffs were unable to consult with the attorneys who already knew the case, especially Att #3, who
plaintiffs'
was best attorney at the defendant's firm, him being very familiar with the case and up to speed with the
progress. Plaintiffs were unable to follow this attorney, who knew their case, since the defendant did not inform
plaintiffs about his departure.
22. This caused tremendous delays, duplicate and overlapping work, same work being done repeatedly over
Plaintiffs'
again, causing reoccurring costs and duplicate charges for the plaintiffs. case was left in a limbo for
several months between attorney changes at the defendant's law firm and during these months nothing moved
plaintiffs' Plaintiffs'
forward in case. case was stalled and delayed, did not proceed quickly as promised by the
defendant. The defendant did not communicate and inform the plaintiffs about the easons for delays and gaps in
communication about the progress in the case.
23. Plaintiffs were not kept informed properly on the status of their case by defendant.
plaintiffs'
24. Plaintiffs madeseveral attempts to communicate via e-mail but received no responses to
plaintiffs'
questions from Att #4 (Cheryl Berger).
25. On May3"5, 2023, plaintiffs sent a Letter Of Concern to defendant regarding why the case was not
moving forward and seriously questioned how the case was being handled by the defendant.
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Coincidentally, the May invoice to plaintiffs, from the defendant, indicated that the defendant had initiated extensive
"just" plaintiffs'
work, as of May 2nd, 2023 date on the invoice, the day before the Iztter of Concern was e-mailed
to the defendant (Atts #4 and #5 and several other employees) and that the defendant had started to review the pre-
discovery response documents, which had been received four months earlier, on January 3rd, 2023.
26. On the June 1, 2023, plaintiff attends, with her brother-in-law (Mr. Matti Tukkimies), a meeting about
their case with defendant's Att #4, who according to an e-mail and invoice/billing info, had been working diligently
plaintiffs'
already for one month on case and had been drafting the deficiency letter. But defendant's Att #4 was
unable to demonstrate any substantiation of being knowledgeable about the case, she was unable to nameany single
plaintiffs'
business company involved in case. Plaintiff noticed that the defendant/Att #4 (supervisor) was
unfamiliar with the case in regards to case progress and neither being up to speed. Plaintiff's brother-in- law, who
was at the meeting, witnessed the same about Att #4. (Matti Tukkimies witness statement is available).
27. At this meeting defendant promised to provide plaintiffs a copy of the deficiency letter within ten days,
plaintiffs'
so that plaintiffs could check, makeadditions and approve this letter, before it was sent to original case's
opponents. This did not occur in the promised time period, plaintiffs received a copy much later and therefore were
unable to makeall the necessary corrections.
28. On July 12, 2023, the defendant sent the incomplete and unapproved letter, containing mistakes,
plaintiffs'
without knowledge and without their agreement.
29. After the retainer fee, $7500.00 had been used, plaintiffs had continued to makepayments to the
defendant until the end of July 2023, totaling approximately to $ 30,000 with minimal results on the defendant's
part. Over two years had gone by and pre-discovery had not been completed.
30. On August 8th, 2023, Plaintiffs requested defendant (Att 5), to provide a budget/estimate based on the
planned work, estimated expenses involved and appropriate legal strategies visioned by the defendant, for plaintiffs
to plan and do the fundraising to cover these costs. The budget/estimate was promised by August 21st, 2023 by the
defendant.
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31. This budget/estimate plan was never provided to the plaintiffs. Instead the defendant initiated a process
of removing plaintiffs as a client due to a non-payment, on August 22, 2023, just prior to the next status conference
with the judge, scheduled for September 26, 2023.
32. By reasons of the facts above and circumstances above, the defendant has breached the retainer
agreement dated on July 13th, 2021. The defendant violated the rules of lawyer's professional conduct and client's
rights, caused plaintiff to suffer financial hardship due to defendant's abuse, by overcharging for legal services
provided, violating attorney-client codes of professional conduct, misrepresenting facts, dishonesty, deficiency in
providing professional legal advice in plaintiff's case and lack of communication on manyfronts. The defendant has
also caused severe mental strain to the plaintiffs by the following: their unprofessional attitude; discrimination
tactics due to plaintiff not being a native English speaker; straight abuse of plaintiff's situation and person, plaintiff's
moneyand time by stalling and intentionally delaying the case work; not doing what the defendant had committed to
do by specific time frames; constantly missing promised deadlines on the work needed to be done; not provided
plaintiffs' plaintiffs'
access to case documents and or full access to their case file; not providing advice in the best
interest; not communicating about problems, changes in attorneys, MSTeams meetings, scheduled meetings or the
best legal strategies for the plaintiffs. Plaintiffs have been forced to look for legal advice and retain new legal
representation from other sources and eventually hire a new attorney from another law firm from the fall of 2023
onward. The plaintiffs have new financial obligations to their new legal representation to get their case properly
dealt with. The financial damage, that the defendant has caused by their unprofessional actions, overcharging and
plaintiffs' plaintiffs'
burgeoning expenses in unjustified manner, for defendant's deficient services in case, while
being defendant's client previously, between July 2021 and August 2023, is unacceptable and must be corrected.
33. By reasons of the facts and the circumstances above, the plaintiffs have been actually damaged and
been damaged also financially, by the defendant, in the sumof $ 16,130 (sixteen thousand and one hundred and
thirty dollars) and anything the court sees as reasonable. WHEREFORE,
the plaintiff demands a judgment against
the defendant in the sum of $16,130 plus interest from February 2023, costs and disbursements, together with any
relief Court finds to be just and proper.
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Dated: June 14th, 2024
Signature
OonaHaaranen-Schort, as Attorney in Fact for Seymour Schorr
54180 Main Road Unit A, Southold NewYork, 11971
917-859-6699
VERIFICATION
OonaHaarane -
chorr, as Attorney in Fact for Seymour Schorr
h l{ hein p duly sworn deposes and
says:
I amthe plaintiff in the above-entitled action. I have read the foregoing complaint and know the contents thereof.
The same is true to my knowledge, except as to matters I believe them to be true.
Signature
Print name
Sworn to before methis
u TRA JOANNE
7 NOTARY
PUBLI , STATEOFNEW
YORK
NO. 04TR6305799
QUAUFIEDIN SUFFOLKCOUNTY
COMMISSIONEXPlRES JUNE9, 20 k
Notary Public
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SUPREMECOURTOFTHESTATEOFNEWYORK
COUNTYOFSUFFOLK
_____---------------------------------------X
Oona Haaranen-Schorr, as Attomey Fact for Seymour Schorr
in
hda Na
Petitioner(s)/Plaintiff(s),
PART130
- against - · CERTIFICATION
Lieb at Law, P.C.
Respondent(s)/Defendant(s).
________________________________________Ç
CERTIFICATION: I hereby certify that all of the papers that I have filed or submitted to the
court in this action/proceeding are not frivolous as defined in subsection (c) of Section 130-1.1
of the Rules of the Chief Administrator of the Co .
Dated:
June 14, 2024
SIGNATURE
Print or type name below signature
A-
o c
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Preview
FILED: SUFFOLK COUNTY CLERK 06/14/2024 02:33 PM INDEX NO. 614693/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/14/2024 SUPREMECOURTOFTHESTATEOFNEWYORK Index No.: COUNTYOFSUFFOLK Date Summonsfiled: -------------------------------------------------------------X Plaintiffdesignates SUFFOLK County as the place of trial Oona Haaranen-Schorr, as Attorney in Fact for Seymour Schort The basis ofvenue is: Plaintiff, -against- SUMMONS Plaintif/Defendant resides at: Oons & Seymour Schorr 54180 Main Road, Unit A Lieb at Law, P.C· Defendant. Southold, NY 11971 To the above named Defendant: YOUAREHEREBY SUMMONED to answer the complaint in this action and to serve a copy of your answer on the O Plaintif ORQ Plaintiff's twenty (20) days Attorney(s) within after the service of this summons,exclusive ofthe day of service, where service is made by delivery upon you personally within the state, or within thirty (30) days after completion of service where service is made in any other manner. In case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. Dated June 14, 2024 O Plaintif Q Attorney(s) for Plaintiff Address: 5q 96 / t½ ain Ñon t) , Ori Phone No.: 917-859-6699 1 of 9 FILED: SUFFOLK COUNTY CLERK 06/14/2024 02:33 PM INDEX NO. 614693/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/14/2024 SUPREMECOURTOFTHESTATEOF NEWYORK COUNTYOFSUFFOLK --------------------------x OonaHaaranen-Schorr, as Attorney in Fact for Seymour Schorr Plaintiffs, Index No. /20__ - against- COMPLAINT Lieb at Law, P.C. Defendant ________-----_____ _ _ _ ______Ç COURTOFTHE STATEOFNEW THESUPREME YORK The complaint of the plaintiffs, OonaHaaranen-Schorr and Seymour Schorr respectfully shows and alledges as follows: 1. Plaintiffs, OonaHaaranen-Schort, as Attorney in Fact forSeymour Schort, is a resident of State of New York. Oonaand Seymour Schorr reside at 24180 Main Road, Unit A, Southold, NewYork 11971. 2. The defendant herein Lieb at Law, P.C., has a principal place of business at 308 W. Main Street, Suite 100, Smithtown, NewYork 11787. Defendant is engaged in business of providing legal services. plaintiffs' 3. Plaintiffs Schorr desired to have a fair pay out proposal, which would take into consideration ownership interests in entities ownedin conjunction with Mr. Schort, his daughters and other related parties. Plaintiffs' and defendant (Andrew Lieb, Managing Partner) discussed specifications for this proceeding and how to plaintiffs' best obtain necessary information quickly taking into consideration age (90/92), 24/7 care requirements Plaintiffs' and limited funds. recurring monthly payments, from Mr. Schorr's other relatives as his business partners, had been abruptly discontinued in September 2020, nine months prior to a very questionable payout offer from these business partners/relatives. 4. July 13th, 2021 plaintiffs signed a retainer agreement with Lieb at Law P.C. for accounting proceeding. Plaintiffs paid defendant the mtainer fee of $7500. 5. About three months later, on October 12th, 2021 the action was commencedwhendefendant Lieb Law plaintiffs' P.C. (Vasilios (Billy) Skulikidis, hereafter Att.#1) filed a Verified Summonsand Complaint, in original case (index No: 619186/21). 2 of 9 FILED: SUFFOLK COUNTY CLERK 06/14/2024 02:33 PM INDEX NO. 614693/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/14/2024 6. About 2.5 months later, on January 7th, Att.#1 provided plaintiff with a copy of the first discovery demands and requested plaintiff to create a list of specific demands to add to the demand document. Plaintiff had last communication with Att#1 February 4th, 2022. 7. About February 22nd, 2022 plaintiff makes several attempts to connect with the Att #1 in order to provide him with the promised list and documents, but cannot locate him. Instead the defendant's secretary, Suzanne plaintiffs' Damante, starts to accept documents. 8. Approximately three months later, in April 2022, plaintiffs finds out that, Att. #1 had left the defendant's law firm permanently, but nobody from the defendant's firm bothered to inform the plaintiff about this. 9. Around the end of April, 2022, defendant's secretary Suzanne Demante confirmed that another plaintiffs' supervisor/Lieb at Law P.C. partner, Mordy Yankovitch, (hereafter Att #2) was looking after case. plaintiffs' 10. Nothing in case was moving forward, until the defendant was assigned to another attorney, John Scherer (hereafter Att #3), who contacted the plaintiff on August 12th, 2022 and who continued reworking the same demanddocuments provided to plainti ffs by their Att #1 in January 7th, 2022, eight months previously. Plaintiffs were charged twice for these same demanddocuments (first time in December 2021 by Att #1), the discovery demands, which were finally submitted to the defendant in plaintiffs original case in August 25, 2022 (and charged for the second time in August 2022 ) with additional pages added by Att #3. 11. On December 21, 2022, one and half years later since signing the agreement with defendant's law firm, plaintiffs finally received 400 pages of a discovery document dump (unorganized response without indications Plaintiffs' what each document referred and responded to) for the 8 (eight) businesses in the plaintiff's original case. plaintiffs' defendants' Att #3 requested an organized response from the original case attorney, which they promised to provide. defendants' 12. OnJanuary 3, 2023, the attorney (in the original law case) provided these organized documents to defendant, Lieb Law P.C, who failed to produce and provide these documents to plaintiffs, even when the plaintiffs were charged for filing these documents on that very day. 3 of 9 FILED: SUFFOLK COUNTY CLERK 06/14/2024 02:33 PM INDEX NO. 614693/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/14/2024 13. OnJanuary 18, 2023 plaintiffs received an e-mail regarding ADRfrom a fourth attorney, Cheryl Berger, (hereafter Att # 4) who the plaintiffs were not familiar with. 14. Since January 26, 2023, the plaintiffs sent several email requests to the defendants Att's #2, #3 and #4 as well as to secretary Suzanne Damante in order to receive the promised organized discovery responses and also to inquire if the discovery responses contained enough information to moveto ADRor litigation. The plaintiffs also inquired if their previous attorney, Att #3, had left Lieb at law P.C. because he was unreachable by the plaintiffs. 15. The Plaintiffs received no answers to these and to their other specific questions posed to the defendant. Instead the defendant responded with answers to questions that were not asked by the plaintiffs, along with distortions and falsifications, claiming that the defendant had answered already these questions by plaintiffs, which they actually had not answered at all. 16. Because the plaintiffs did not receive professional guidance from the defendant, the plaintiffs could not makean informed decision regarding ADRor litigation neither did plaintiffs know what was being done with their case. 17. The plaintiffs, on their own accord, without any notice from the defendant, learned from the internet about the scheduled MSTeams conference concerning the plaintiffs' own case, with the Judge on March 30, 2023, attorneys' and that clients also are actually allowed to attend such conferences. The defendant had failed to inform plaintiffs about any of this. 18. At this Judge's conference, the plaintiff found out, from the defendants', Att # 4 and from yet another new attorney to plaintiffs, Natalie Donaldson (hereafter Att # 5), the reasons for the defendant's delays with the plaintiffs' Plaintiffs' case. Att # 3 had indeed left the defendant's law firm in January 2023 without informing plaintiffs. The other reasons for delays were stated by Att#5 at the meeting with the judge as: plaintiff's language plaintiffs' barrier, the need for communication to be in writing (which had not been an issue for Att#1 and Att #3), plaintiffs' and that newly appointed attorney at defendant's firm, Att #4, was busy with another case and so unable to attend the judge meeting and that defendant (Att #4) now required yet more time to review the discovery responses received in January 3, 2023. 4 of 9 FILED: SUFFOLK COUNTY CLERK 06/14/2024 02:33 PM INDEX NO. 614693/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/14/2024 19. The defendant blamed the plaintiff's language barrier as the main cause for the delays in the case, when in actuality there had been several changes in plaintiffs' representation in attorneys, each mquiring momtime to learn the case and get up to speed; and piling up costs for the plaintiffs to pay. Plaintiff ended up being charged over and over again for the same services paid for already previously, just because the persons (attorneys), handling and familiarizing themselves with the case, kept on changing. 20. Defendant failed to inform plaintiffs about the constant changes in attorneys. Plaintiffs were left in the dark, always surprised to be thrown to an unfamiliar person, next new attorney. Defendant did not inform and tried to hide the fact, that their two previous attorney (Att #1 and Att #3) had left the company. It was months later that the plaintiffs finally figured out the fact, that both of these attorneys had left the defendant's firm for good. 21. Plaintiffs were unable to consult with the attorneys who already knew the case, especially Att #3, who plaintiffs' was best attorney at the defendant's firm, him being very familiar with the case and up to speed with the progress. Plaintiffs were unable to follow this attorney, who knew their case, since the defendant did not inform plaintiffs about his departure. 22. This caused tremendous delays, duplicate and overlapping work, same work being done repeatedly over Plaintiffs' again, causing reoccurring costs and duplicate charges for the plaintiffs. case was left in a limbo for several months between attorney changes at the defendant's law firm and during these months nothing moved plaintiffs' Plaintiffs' forward in case. case was stalled and delayed, did not proceed quickly as promised by the defendant. The defendant did not communicate and inform the plaintiffs about the easons for delays and gaps in communication about the progress in the case. 23. Plaintiffs were not kept informed properly on the status of their case by defendant. plaintiffs' 24. Plaintiffs madeseveral attempts to communicate via e-mail but received no responses to plaintiffs' questions from Att #4 (Cheryl Berger). 25. On May3"5, 2023, plaintiffs sent a Letter Of Concern to defendant regarding why the case was not moving forward and seriously questioned how the case was being handled by the defendant. 5 of 9 FILED: SUFFOLK COUNTY CLERK 06/14/2024 02:33 PM INDEX NO. 614693/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/14/2024 Coincidentally, the May invoice to plaintiffs, from the defendant, indicated that the defendant had initiated extensive "just" plaintiffs' work, as of May 2nd, 2023 date on the invoice, the day before the Iztter of Concern was e-mailed to the defendant (Atts #4 and #5 and several other employees) and that the defendant had started to review the pre- discovery response documents, which had been received four months earlier, on January 3rd, 2023. 26. On the June 1, 2023, plaintiff attends, with her brother-in-law (Mr. Matti Tukkimies), a meeting about their case with defendant's Att #4, who according to an e-mail and invoice/billing info, had been working diligently plaintiffs' already for one month on case and had been drafting the deficiency letter. But defendant's Att #4 was unable to demonstrate any substantiation of being knowledgeable about the case, she was unable to nameany single plaintiffs' business company involved in case. Plaintiff noticed that the defendant/Att #4 (supervisor) was unfamiliar with the case in regards to case progress and neither being up to speed. Plaintiff's brother-in- law, who was at the meeting, witnessed the same about Att #4. (Matti Tukkimies witness statement is available). 27. At this meeting defendant promised to provide plaintiffs a copy of the deficiency letter within ten days, plaintiffs' so that plaintiffs could check, makeadditions and approve this letter, before it was sent to original case's opponents. This did not occur in the promised time period, plaintiffs received a copy much later and therefore were unable to makeall the necessary corrections. 28. On July 12, 2023, the defendant sent the incomplete and unapproved letter, containing mistakes, plaintiffs' without knowledge and without their agreement. 29. After the retainer fee, $7500.00 had been used, plaintiffs had continued to makepayments to the defendant until the end of July 2023, totaling approximately to $ 30,000 with minimal results on the defendant's part. Over two years had gone by and pre-discovery had not been completed. 30. On August 8th, 2023, Plaintiffs requested defendant (Att 5), to provide a budget/estimate based on the planned work, estimated expenses involved and appropriate legal strategies visioned by the defendant, for plaintiffs to plan and do the fundraising to cover these costs. The budget/estimate was promised by August 21st, 2023 by the defendant. 6 of 9 FILED: SUFFOLK COUNTY CLERK 06/14/2024 02:33 PM INDEX NO. 614693/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/14/2024 31. This budget/estimate plan was never provided to the plaintiffs. Instead the defendant initiated a process of removing plaintiffs as a client due to a non-payment, on August 22, 2023, just prior to the next status conference with the judge, scheduled for September 26, 2023. 32. By reasons of the facts above and circumstances above, the defendant has breached the retainer agreement dated on July 13th, 2021. The defendant violated the rules of lawyer's professional conduct and client's rights, caused plaintiff to suffer financial hardship due to defendant's abuse, by overcharging for legal services provided, violating attorney-client codes of professional conduct, misrepresenting facts, dishonesty, deficiency in providing professional legal advice in plaintiff's case and lack of communication on manyfronts. The defendant has also caused severe mental strain to the plaintiffs by the following: their unprofessional attitude; discrimination tactics due to plaintiff not being a native English speaker; straight abuse of plaintiff's situation and person, plaintiff's moneyand time by stalling and intentionally delaying the case work; not doing what the defendant had committed to do by specific time frames; constantly missing promised deadlines on the work needed to be done; not provided plaintiffs' plaintiffs' access to case documents and or full access to their case file; not providing advice in the best interest; not communicating about problems, changes in attorneys, MSTeams meetings, scheduled meetings or the best legal strategies for the plaintiffs. Plaintiffs have been forced to look for legal advice and retain new legal representation from other sources and eventually hire a new attorney from another law firm from the fall of 2023 onward. The plaintiffs have new financial obligations to their new legal representation to get their case properly dealt with. The financial damage, that the defendant has caused by their unprofessional actions, overcharging and plaintiffs' plaintiffs' burgeoning expenses in unjustified manner, for defendant's deficient services in case, while being defendant's client previously, between July 2021 and August 2023, is unacceptable and must be corrected. 33. By reasons of the facts and the circumstances above, the plaintiffs have been actually damaged and been damaged also financially, by the defendant, in the sumof $ 16,130 (sixteen thousand and one hundred and thirty dollars) and anything the court sees as reasonable. WHEREFORE, the plaintiff demands a judgment against the defendant in the sum of $16,130 plus interest from February 2023, costs and disbursements, together with any relief Court finds to be just and proper. 7 of 9 FILED: SUFFOLK COUNTY CLERK 06/14/2024 02:33 PM INDEX NO. 614693/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/14/2024 Dated: June 14th, 2024 Signature OonaHaaranen-Schort, as Attorney in Fact for Seymour Schorr 54180 Main Road Unit A, Southold NewYork, 11971 917-859-6699 VERIFICATION OonaHaarane - chorr, as Attorney in Fact for Seymour Schorr h l{ hein p duly sworn deposes and says: I amthe plaintiff in the above-entitled action. I have read the foregoing complaint and know the contents thereof. The same is true to my knowledge, except as to matters I believe them to be true. Signature Print name Sworn to before methis u TRA JOANNE 7 NOTARY PUBLI , STATEOFNEW YORK NO. 04TR6305799 QUAUFIEDIN SUFFOLKCOUNTY COMMISSIONEXPlRES JUNE9, 20 k Notary Public 8 of 9 FILED: SUFFOLK COUNTY CLERK 06/14/2024 02:33 PM INDEX NO. 614693/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/14/2024 SUPREMECOURTOFTHESTATEOFNEWYORK COUNTYOFSUFFOLK _____---------------------------------------X Oona Haaranen-Schorr, as Attomey Fact for Seymour Schorr in hda Na Petitioner(s)/Plaintiff(s), PART130 - against - · CERTIFICATION Lieb at Law, P.C. Respondent(s)/Defendant(s). ________________________________________Ç CERTIFICATION: I hereby certify that all of the papers that I have filed or submitted to the court in this action/proceeding are not frivolous as defined in subsection (c) of Section 130-1.1 of the Rules of the Chief Administrator of the Co . Dated: June 14, 2024 SIGNATURE Print or type name below signature A- o c 9 of 9