Preview
FILED: RICHMOND COUNTY CLERK 02/17/2021 05:53 PM INDEX NO. 150360/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/17/2021
SUPREME COURT OF THE STATE OF NEW YORK Index No.:
COUNTY OF RICHMOND
BLUEPOINT BUSINESS FUNDING,
Plaintiff, SUMMONS
-against-
Plaintiff's address is:
CAMP JACKSON MOTORS INC and 525 Washington Blvd., Suite 2200
CAR COMPANY OF MILLSTADT and Jersey City, NJ 07310
ROBERT STENGER,
Defendants.
TO THE ABOVE-NAMED DEFENDANTS:
YOU ARE HEREBY SUMMONED and required to serve upon Plaintiff attorney, 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 summa= the date of service. If the s ens was not
excluding 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 law.
by
If you do not serve an answer to the attached complaint within the applicable time
Esta+ion stated above, a judgment may be entered against you, by default, for the relief deanded
in the complaint, without further notice to you.
The basis for venue is pursuañt to the Contract entered into between the parties.
Dated: Toms River, New Jersey
February 17, 2021
The nature of this action is breach of contract. S
The relief sought is money damages.
Yehuda Klein, Esq.
Attorney for Plaintif
112 West 34th Street 18th Floor PMB 27813
New York, New York 10120
Phone: (347) 899-4025
Email: jay.klein@abfservicing.com
Defendants to be served:
CAMP JACKSON MOTORS INC, 630 E Washington St, Millstadt, IL 62260
CAR COMPANY OF MILLSTADT, 630 E Washingtoñ St, Millstadt, IL 62260
ROBERT STENGER, 1331 Lakeview Dr., Waterloo, IL 62298
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF RICHMOND
BLUEPOINT BUSINESS FUNDING, Index No.:
Plaintiff,
-against- VERIFIED
COMPLAINT
CAMP JACKSON MOTORS INC and
CAR COMPANY OF MILLSTADT and
ROBERT STENGER,
Defendants.
Plaintiff BLUEPOINT BUSINESS FUNDING ("Plaintiff), by itsattorney, Yehuda Klein,
Esq., for itscomplaint herein against CAMP JACKSON MOTORS INC and CAR COMPANY OF
MILLSTADT (collectively, "Campany Defendant") and ROBERT STENGER ("Guarantor")
(Company Defc--dset and Guarantor shall be collectively referred to as "Defen±nts"), alleges as
follows:
The Parties
1. At allrelevant times, Plaintiff was and is an entity organized under the laws of the
United States of America.
2. Upon information and belief, at allrelevant times, Company Dafandant was and is
a organized and under the laws of the State of minnit
cemps-f existing
3. Upon information and belief, at allrelevant times, individual Guarantor was and is
an individal residing in the State of Illinois.
4. Guarañtor is the owner, principal, and/or manager of Company Def=d=t
The Facts
5. On or about August 31, 2020, Plaintiff and Defendants entered into an agreement
(the "Agr==t") vehcrchy Plaintiff agreed to purchase rights to Company Defandant's future
receivables having an agreed upon value of $59,860.00.
6. Pursuant to the Agreement Defendant agreed to excisi. use one
Company cly
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bank account approved by Plaintiff (the "Account") into which the Company Defendant agreed to
deposit all of itsreceipts and from which Plaintiff was authorized to make daily ACH withdrawals
until $59,860.00 was fully paid to Plaintiff.
7. The Agreement provided that in the event Company Defedant used a bank
accent other than the Account, closed the Account without prior authorization of Plaintiff, or
otherwise prcycated Plaintiff from making the agreed upon ACH withdrawals, the Compmy
Defendant was in default of the Agreement,
8. In addition, Guarantor agreed to guarantee any and allascsts owed to Plaintiff
from Company
Dd =3==+ upon Compsñy Defendant's breach in performance of itsAgreement
obligations.
9. Plaintiff remitted the purchase price for the future receivables to Compey
Defendst as agreed and thereby fulfilled allof itsAgreement obligations.
10. On or about November 5, 2020, Defendant blocked Plaintiff's access to
Company
the Accent and therchy prcycñted Plaintiff from making the agreed upon ACH withdrawals and
otherwise defeelted under the terms of the Agreement by breaching itsreprcs=tations and
warranties to Plaintiff in direct violation of the Agraamant
11. Company Defer.dant made payments tGtaling $21,457.00 leaving a balmee of
$38,403.00. In addition, pursuant to the Agreement, Company Defendant incurred a default
account fee in the amount of $2,500.00.
12. Guarañtor is respancihla for all ame'=+s incurred as a result of
Additionally, any
default in the Agreement by Company Defendant.
13. There remains a balance due and owing to Plaintiff on the Agreement in the
a-cst of $40,903.00 plus interest at the statutory rate, costs, disbursements and attorney's fees.
AS AND FOR THE FIRST CAUSE OF ACTION (Breach of Contract)
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14. Plaintiff repeats and realleges each and every allegation contained in paragraphs 1
through 14 of this complsht as though fully set forth at length herein.
15. Upon information and Defendant is still businese
belief, Company conducting
operations and stillcollecting receivables.
16. the course of the Agreement the unpaid sums became due and payable to
During
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 ce=±=i=cd in the
Agreement. Any cutstanding balance owed by the Company Defendant at the time of default
became immediately due and payable.
17. By reason of the foregoing, Plaintiff has suffered damages in the amount of
$40,903.00, plus interest at the statutory rate, costs, disburcements and attorney's fees.
AS AND FOR A SECOND CAUSE OF ACTION (Breach of Guarantee)
18. Plaintiff repeats and realleges each and every allegation contained in paragraphs 1
through 18 of this cc-pl2E± as though fully set forth at length herein.
19. Pursuant to the Agreement, Guarantor guaranteed that Defendsñt would
Company
perform itsobligations thereunder and that Guaranter would be individually, jointly, and severally
liable for any loss suffered by Plaintiff as a result of a breach by Company Defendant.
20. Company Defendant has breached the Agreement as detailed above.
21. By reason of the foregoing, Plaintiff is entitled to judgement against Guarañter
based on G ====±- r's breach of the guarantee in the sum of plus interest at the
$40,903.00,
statutory rate, costs, disbursements and attorney's fees.
AS AND FOR A THIRD CAUSE OF ACTION (Unjust Enrichment)
22. Plaintiff repeats and realleges each and every allegation contained in paragraphs 1
through 22 of this cc-p¹+± as though fully set forth at length herein.
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23. Def--d==h have been unjustly enriched in that they have received the purchase
price for the future receivables, yet have failed to pay the sum of $40,903.00 purmiant to the
Agreement.
24. reason of the foregoing, Plaintiff is entitled to judgment against the Defendants
By
for unjust enrichment in the ameüñt of $40,903.00, plus interest at the statutcry rate, costs,
disbursements and attorney's fees.
Plaintiff requests judgement againct Defe-ann±= as follows:
WHEREFORE,
(i) On the firstcause of action of the complaint, Plaintiff reqücats judgement
against Campsñy Defendant in the amount of $40,903.00, plus interest at the
statutory rate, costs, disbursements and attorney's fees;
(ñ) On the second cause of action of the complaint, Plaintiff requests
judgement against Guaranter in the amount of $40,903.00, plus interest at the
statutory rate, costs, disbursements and attorney's fees;
(iii) On the third cause of action of the complaint, Plaintiff requests
judgemcat against Dafandants in an amenat of $40,903.00, plus interest at the
statutory rate, costs, disbursements and attorney's fees;
(iv) For such other and further relief as this Court deems just and proper.
Dated: Toms River, New Jersey
February 17, 2021
Yehuda Klein, Esq.
Attorney for Plaintly
112 West 34th Street 18th Floor PMB 27813
New York, New York 10120
Phone: (347) 899-4025
Email: jay.klein@abfservicing.com
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SUPREME COURT OF THE STATE OF NEW YORK Index No.:
COUNTY OF RICHMOND
BLUEPOINT BUSINESS FUNDING, VERIFICATION
Plaintiff, BY A PARTY
-against-
CAMP JACKSON MOTORS INC and
CAR COMPANY OF MILLSTADT and
ROBERT STENGER,
De£=dants.
STATE OF NEW JERSEY )
) ss.:
COUNTY OF HUDSON )
ELIE FRIEDMAN, being duly sworn states that he is an Authorized Officer of Plaintiff in
the within action. I have read the Verified Complaint and know the c,m+=+c the
foregoing thereof;
same is true to own except as to matters therciñ stated to be alleged on information
my knowledge,
and belief, and as to those matters, I believe them to be true.
The foregoing stat-+s are true under penalties of perjury.
Elie Friedman,
On February 17, 2021, before me personally appeared ELIE FRIEDMAN, personally known to me
or proved to me on the basis of satisfactory evidence to be the individual whose name is subscribed
to the within instramcat and acknowledged to me that he executed the same in his capacity, and that
by his sig-atre on the instrument, the individual, or the person or entity upon behalf of which the
individual acted, executed the instrument.
NASTACIA REDHEAD
Notary Public, State of New Jersey
Comm. No. 50106834
Qualified in Hudson County
My Commission Expires June 12, 2024
Notary Public, State of New Jersey
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF RICHMOND
BLUEPOINT BUSINESS FUNDING, Index No.:
Plaintiff,
-against-
CAMP JACKSON MOTORS INC and
CAR COMPANY OF MILLSTADT and
ROBERT STENGER,
Defendants.
NOTICE OF ELECTRONIC FILING (Mandatory Case, Uniform Rule §202.5-bb)
YOU HAVE RECEIVED THIS NOTICE because:
1) The Phintiff/Petitioner, whose name is listedabove, has filed this case using the
New York State Courts E-hg system ("NYSCEF"), and
2) You are a Defedent/Respondent (a party) in this case.
• If you are represented an - Give this Notice to your atteracy.
by attorney
Attorneys"
(Attorneys: see "Information for below).
• If you are not represented an attorney: You will be served with all
by
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:
• and your documents
serving filing electronically
• free access to view and print your e-filed deenmarts
• your number of trips to the courthouse
limiting
• court fees on-line (credit card
paying any needed)
To register for e-filing or for more information about how e-filing works:
• visit: www.nycenits.gov/efile-unrepresented or
• contact the Clerk's Office or Center at the court where the case was filed.
Help
Court contact information can be found at www.nycourts.gov
To find legal information to help you represent yourself visit www.nycourthelp.gov.
1
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Information for Attorneys (E-filing is Mandatory for Attorneys)
An attorney representing a party who is served with thisnotice must either:
1) immediately record his or her representation within the e-filed matter on the NYSCEF
site www.nycourts.gov/efile; or
2) file the Notice of Opt-Out form with the clerk of the court where this action is pending
and serve on allparties. Exemptions from -anda±nry e-filing are E-ited to attorneys who certify
in good faith that they lack the co-puts hardware and/or scanner and/or internet connection or
that they lack (along with all employees subject to their direction) the kaswledge to epeate such
equipment. [Section 202.5-bb(e)]
• For additional infhr-=stice about electronic and to create a NYSCEF account,
filing
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 17, 2021
Toms River, New Jersey
Yehuda Klein, Esq.
Attorney for Plaintly
112 West 34th Street 18th Floor PMB 27813
New York, New York 10120
Phone: (347) 899-4025
Email: jay.klein@abfservicing.com
To:
CAMP JACKSON MOTORS INC, 630 E Washington St, Millstadt, IL 62260
CAR COMPANY OF MILLSTADT, 630 E Wa.d ingsñ St, Millstmit, IL 62260
ROBERT STENGER, 1331 Lakeview Dr., Waterloo, IL 62298
2
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Index No. Year: 2021 Hon.
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF RICHMOND
BLUEPOINT BUSINESS FUNDING,
Plaintiff,
-against-
CAMP JACKSON MOTORS INC and
CAR COMPANY OF MILLSTADT and
ROBERT STENGER,
Defendants.
SUMMONS, VERIFIED COMPLAINT and NOTICE OF ELECTRONIC FILING
Yehuda Klein, Esq.
Attorney for Plaintif
Opice and Post Office Address, Telephone
112 West 34th Street 18th Floor PMB 27813
New York, New York 10120
Phone: (347) 899-4025
Email: jay.klein@abfservicing.com
Pursuant to 22 NYCRR 130-1J, the undersigned, an attorney admitted to practice in the courts of New York State,
certijìés that, upon information and belief and reasonable inquiry, the contentions contained in the annexed
document are not frivolous.
Dated: February 17, 2021
Signature:
Yehuda Klein, 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: RICHMOND COUNTY CLERK 02/17/2021 05:53 PM INDEX NO. 150360/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/17/2021 SUPREME COURT OF THE STATE OF NEW YORK Index No.: COUNTY OF RICHMOND BLUEPOINT BUSINESS FUNDING, Plaintiff, SUMMONS -against- Plaintiff's address is: CAMP JACKSON MOTORS INC and 525 Washington Blvd., Suite 2200 CAR COMPANY OF MILLSTADT and Jersey City, NJ 07310 ROBERT STENGER, Defendants. TO THE ABOVE-NAMED DEFENDANTS: YOU ARE HEREBY SUMMONED and required to serve upon Plaintiff attorney, 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 summa= the date of service. If the s ens was not excluding 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 law. by If you do not serve an answer to the attached complaint within the applicable time Esta+ion stated above, a judgment may be entered against you, by default, for the relief deanded in the complaint, without further notice to you. The basis for venue is pursuañt to the Contract entered into between the parties. Dated: Toms River, New Jersey February 17, 2021 The nature of this action is breach of contract. S The relief sought is money damages. Yehuda Klein, Esq. Attorney for Plaintif 112 West 34th Street 18th Floor PMB 27813 New York, New York 10120 Phone: (347) 899-4025 Email: jay.klein@abfservicing.com Defendants to be served: CAMP JACKSON MOTORS INC, 630 E Washington St, Millstadt, IL 62260 CAR COMPANY OF MILLSTADT, 630 E Washingtoñ St, Millstadt, IL 62260 ROBERT STENGER, 1331 Lakeview Dr., Waterloo, IL 62298 1 of 10 FILED: RICHMOND COUNTY CLERK 02/17/2021 05:53 PM INDEX NO. 150360/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/17/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF RICHMOND BLUEPOINT BUSINESS FUNDING, Index No.: Plaintiff, -against- VERIFIED COMPLAINT CAMP JACKSON MOTORS INC and CAR COMPANY OF MILLSTADT and ROBERT STENGER, Defendants. Plaintiff BLUEPOINT BUSINESS FUNDING ("Plaintiff), by itsattorney, Yehuda Klein, Esq., for itscomplaint herein against CAMP JACKSON MOTORS INC and CAR COMPANY OF MILLSTADT (collectively, "Campany Defendant") and ROBERT STENGER ("Guarantor") (Company Defc--dset and Guarantor shall be collectively referred to as "Defen±nts"), alleges as follows: The Parties 1. At allrelevant times, Plaintiff was and is an entity organized under the laws of the United States of America. 2. Upon information and belief, at allrelevant times, Company Dafandant was and is a organized and under the laws of the State of minnit cemps-f existing 3. Upon information and belief, at allrelevant times, individual Guarantor was and is an individal residing in the State of Illinois. 4. Guarañtor is the owner, principal, and/or manager of Company Def=d=t The Facts 5. On or about August 31, 2020, Plaintiff and Defendants entered into an agreement (the "Agr==t") vehcrchy Plaintiff agreed to purchase rights to Company Defandant's future receivables having an agreed upon value of $59,860.00. 6. Pursuant to the Agreement Defendant agreed to excisi. use one Company cly 1 2 of 10 FILED: RICHMOND COUNTY CLERK 02/17/2021 05:53 PM INDEX NO. 150360/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/17/2021 bank account approved by Plaintiff (the "Account") into which the Company Defendant agreed to deposit all of itsreceipts and from which Plaintiff was authorized to make daily ACH withdrawals until $59,860.00 was fully paid to Plaintiff. 7. The Agreement provided that in the event Company Defedant used a bank accent other than the Account, closed the Account without prior authorization of Plaintiff, or otherwise prcycated Plaintiff from making the agreed upon ACH withdrawals, the Compmy Defendant was in default of the Agreement, 8. In addition, Guarantor agreed to guarantee any and allascsts owed to Plaintiff from Company Dd =3==+ upon Compsñy Defendant's breach in performance of itsAgreement obligations. 9. Plaintiff remitted the purchase price for the future receivables to Compey Defendst as agreed and thereby fulfilled allof itsAgreement obligations. 10. On or about November 5, 2020, Defendant blocked Plaintiff's access to Company the Accent and therchy prcycñted Plaintiff from making the agreed upon ACH withdrawals and otherwise defeelted under the terms of the Agreement by breaching itsreprcs=tations and warranties to Plaintiff in direct violation of the Agraamant 11. Company Defer.dant made payments tGtaling $21,457.00 leaving a balmee of $38,403.00. In addition, pursuant to the Agreement, Company Defendant incurred a default account fee in the amount of $2,500.00. 12. Guarañtor is respancihla for all ame'=+s incurred as a result of Additionally, any default in the Agreement by Company Defendant. 13. There remains a balance due and owing to Plaintiff on the Agreement in the a-cst of $40,903.00 plus interest at the statutory rate, costs, disbursements and attorney's fees. AS AND FOR THE FIRST CAUSE OF ACTION (Breach of Contract) 2 3 of 10 FILED: RICHMOND COUNTY CLERK 02/17/2021 05:53 PM INDEX NO. 150360/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/17/2021 14. Plaintiff repeats and realleges each and every allegation contained in paragraphs 1 through 14 of this complsht as though fully set forth at length herein. 15. Upon information and Defendant is still businese belief, Company conducting operations and stillcollecting receivables. 16. the course of the Agreement the unpaid sums became due and payable to During 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 ce=±=i=cd in the Agreement. Any cutstanding balance owed by the Company Defendant at the time of default became immediately due and payable. 17. By reason of the foregoing, Plaintiff has suffered damages in the amount of $40,903.00, plus interest at the statutory rate, costs, disburcements and attorney's fees. AS AND FOR A SECOND CAUSE OF ACTION (Breach of Guarantee) 18. Plaintiff repeats and realleges each and every allegation contained in paragraphs 1 through 18 of this cc-pl2E± as though fully set forth at length herein. 19. Pursuant to the Agreement, Guarantor guaranteed that Defendsñt would Company perform itsobligations thereunder and that Guaranter would be individually, jointly, and severally liable for any loss suffered by Plaintiff as a result of a breach by Company Defendant. 20. Company Defendant has breached the Agreement as detailed above. 21. By reason of the foregoing, Plaintiff is entitled to judgement against Guarañter based on G ====±- r's breach of the guarantee in the sum of plus interest at the $40,903.00, statutory rate, costs, disbursements and attorney's fees. AS AND FOR A THIRD CAUSE OF ACTION (Unjust Enrichment) 22. Plaintiff repeats and realleges each and every allegation contained in paragraphs 1 through 22 of this cc-p¹+± as though fully set forth at length herein. 3 4 of 10 FILED: RICHMOND COUNTY CLERK 02/17/2021 05:53 PM INDEX NO. 150360/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/17/2021 23. Def--d==h have been unjustly enriched in that they have received the purchase price for the future receivables, yet have failed to pay the sum of $40,903.00 purmiant to the Agreement. 24. reason of the foregoing, Plaintiff is entitled to judgment against the Defendants By for unjust enrichment in the ameüñt of $40,903.00, plus interest at the statutcry rate, costs, disbursements and attorney's fees. Plaintiff requests judgement againct Defe-ann±= as follows: WHEREFORE, (i) On the firstcause of action of the complaint, Plaintiff reqücats judgement against Campsñy Defendant in the amount of $40,903.00, plus interest at the statutory rate, costs, disbursements and attorney's fees; (ñ) On the second cause of action of the complaint, Plaintiff requests judgement against Guaranter in the amount of $40,903.00, plus interest at the statutory rate, costs, disbursements and attorney's fees; (iii) On the third cause of action of the complaint, Plaintiff requests judgemcat against Dafandants in an amenat of $40,903.00, plus interest at the statutory rate, costs, disbursements and attorney's fees; (iv) For such other and further relief as this Court deems just and proper. Dated: Toms River, New Jersey February 17, 2021 Yehuda Klein, Esq. Attorney for Plaintly 112 West 34th Street 18th Floor PMB 27813 New York, New York 10120 Phone: (347) 899-4025 Email: jay.klein@abfservicing.com 4 5 of 10 FILED: RICHMOND COUNTY CLERK 02/17/2021 05:53 PM INDEX NO. 150360/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/17/2021 SUPREME COURT OF THE STATE OF NEW YORK Index No.: COUNTY OF RICHMOND BLUEPOINT BUSINESS FUNDING, VERIFICATION Plaintiff, BY A PARTY -against- CAMP JACKSON MOTORS INC and CAR COMPANY OF MILLSTADT and ROBERT STENGER, De£=dants. STATE OF NEW JERSEY ) ) ss.: COUNTY OF HUDSON ) ELIE FRIEDMAN, being duly sworn states that he is an Authorized Officer of Plaintiff in the within action. I have read the Verified Complaint and know the c,m+=+c the foregoing thereof; same is true to own except as to matters therciñ stated to be alleged on information my knowledge, and belief, and as to those matters, I believe them to be true. The foregoing stat-+s are true under penalties of perjury. Elie Friedman, On February 17, 2021, before me personally appeared ELIE FRIEDMAN, personally known to me or proved to me on the basis of satisfactory evidence to be the individual whose name is subscribed to the within instramcat and acknowledged to me that he executed the same in his capacity, and that by his sig-atre on the instrument, the individual, or the person or entity upon behalf of which the individual acted, executed the instrument. NASTACIA REDHEAD Notary Public, State of New Jersey Comm. No. 50106834 Qualified in Hudson County My Commission Expires June 12, 2024 Notary Public, State of New Jersey 5 6 of 10 FILED: RICHMOND COUNTY CLERK 02/17/2021 05:53 PM INDEX NO. 150360/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/17/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF RICHMOND BLUEPOINT BUSINESS FUNDING, Index No.: Plaintiff, -against- CAMP JACKSON MOTORS INC and CAR COMPANY OF MILLSTADT and ROBERT STENGER, Defendants. NOTICE OF ELECTRONIC FILING (Mandatory Case, Uniform Rule §202.5-bb) YOU HAVE RECEIVED THIS NOTICE because: 1) The Phintiff/Petitioner, whose name is listedabove, has filed this case using the New York State Courts E-hg system ("NYSCEF"), and 2) You are a Defedent/Respondent (a party) in this case. • If you are represented an - Give this Notice to your atteracy. by attorney Attorneys" (Attorneys: see "Information for below). • If you are not represented an attorney: You will be served with all by 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: • and your documents serving filing electronically • free access to view and print your e-filed deenmarts • your number of trips to the courthouse limiting • court fees on-line (credit card paying any needed) To register for e-filing or for more information about how e-filing works: • visit: www.nycenits.gov/efile-unrepresented or • contact the Clerk's Office or Center at the court where the case was filed. Help Court contact information can be found at www.nycourts.gov To find legal information to help you represent yourself visit www.nycourthelp.gov. 1 7 of 10 FILED: RICHMOND COUNTY CLERK 02/17/2021 05:53 PM INDEX NO. 150360/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/17/2021 Information for Attorneys (E-filing is Mandatory for Attorneys) An attorney representing a party who is served with thisnotice must either: 1) immediately record his or her representation within the e-filed matter on the NYSCEF site www.nycourts.gov/efile; or 2) file the Notice of Opt-Out form with the clerk of the court where this action is pending and serve on allparties. Exemptions from -anda±nry e-filing are E-ited to attorneys who certify in good faith that they lack the co-puts hardware and/or scanner and/or internet connection or that they lack (along with all employees subject to their direction) the kaswledge to epeate such equipment. [Section 202.5-bb(e)] • For additional infhr-=stice about electronic and to create a NYSCEF account, filing 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 17, 2021 Toms River, New Jersey Yehuda Klein, Esq. Attorney for Plaintly 112 West 34th Street 18th Floor PMB 27813 New York, New York 10120 Phone: (347) 899-4025 Email: jay.klein@abfservicing.com To: CAMP JACKSON MOTORS INC, 630 E Washington St, Millstadt, IL 62260 CAR COMPANY OF MILLSTADT, 630 E Wa.d ingsñ St, Millstmit, IL 62260 ROBERT STENGER, 1331 Lakeview Dr., Waterloo, IL 62298 2 8 of 10 FILED: RICHMOND COUNTY CLERK 02/17/2021 05:53 PM INDEX NO. 150360/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/17/2021 Index No. Year: 2021 Hon. SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF RICHMOND BLUEPOINT BUSINESS FUNDING, Plaintiff, -against- CAMP JACKSON MOTORS INC and CAR COMPANY OF MILLSTADT and ROBERT STENGER, Defendants. SUMMONS, VERIFIED COMPLAINT and NOTICE OF ELECTRONIC FILING Yehuda Klein, Esq. Attorney for Plaintif Opice and Post Office Address, Telephone 112 West 34th Street 18th Floor PMB 27813 New York, New York 10120 Phone: (347) 899-4025 Email: jay.klein@abfservicing.com Pursuant to 22 NYCRR 130-1J, the undersigned, an attorney admitted to practice in the courts of New York State, certijìés that, upon information and belief and reasonable inquiry, the contentions contained in the annexed document are not frivolous. Dated: February 17, 2021 Signature: Yehuda Klein, Esq. To: Attorney(s) for Service of a copy of the within is hereby admitted. Dated: Attorney(s) for 9 of 10 FILED: RICHMOND COUNTY CLERK 02/17/2021 05:53 PM INDEX NO. 150360/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 02/17/2021 10 of 10