On July 23, 2021 a
Party Notice
was filed
involving a dispute between
Rmp Technik, Inc., D B A Penn Yan Aero,
and
Andrew Anderson,
Falcon Flying Club,
for Commercial - Contract
in the District Court of Yates County.
Preview
FILED: YATES COUNTY CLERK 08/18/2021 12:41 PM INDEX NO. 2021-5186
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 08/18/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF YATES INDEX NO.: 2021-5186
X
RMP Technik, Inc., d/b/a PENN YAN AERO,
Plaintiff,
NOTICE OF APPEARANCE
-against- &
DEMAND FOR COMPLAINT
Falcon Flying Club and Andrew Anderson,
Defendants.
X
PLEASE TAKE NOTICE that the undersigned has been retained as counsel of record for
Defendants, FALCON FLYING CLUB and ANDREW ANDERSON and hereby appear in this
action on behalf of the Defendants.
Defendants hereby demand, in accordance with CPLR § 3012(b), that you serve a copy of
the complaint and all notices and other previously filed papers in this action personally upon all
the Defendants named in this action, in accordance with CPLR §308 at the addresses stated below.
Falcon Flying Club Andrew Anderson
152 Brittany Lane 7 Falcon Drive
Senoia, Georgia 30276 Peachtree City, Georgia 30269
Dated: August 18, 2021 __________________________
Rachel Lee Dreher, Esq.
Attorney for the Defendants
631 Lucerne Avenue, Suite 53
Lake Worth Beach, FL 33460
561.801.8661
rachel@dreherlawgroup.com
TO:
KMA Zuckert LLC
Eugene Massamillo, Esq.
1350 Broadway, Suite 2410
New York, NY 10018
1 of 3
FILED: YATES COUNTY CLERK 08/18/2021 12:41 PM INDEX NO. 2021-5186
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 08/18/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF YATES INDEX NO.: 2021-5186
X
RMP Technik, Inc., d/b/a PENN YAN AERO,
Plaintiff,
CERTIFICATE OF SERVICE
-against-
Falcon Flying Club and Andrew Anderson,
Defendants.
X
This is to certify that I am a member in good standing of the Bar of this Court and that on
August 18, 2021; I served a copy of Defendants’ Notice of Appearance and Demand for Complaint
by e-filing the demand through the New York State e-filing portal and service was completed
through the e-filing system upon all parties in this action.
Dated: August 18, 2021 __________________________
Rachel Lee Dreher, Esq.
Attorney for the Defendants
631 Lucerne Avenue, Suite 53
Lake Worth Beach, FL 33460
561.801.8661
rachel@dreherlawgroup.com
2 of 3
FILED: YATES COUNTY CLERK 08/18/2021 12:41 PM INDEX NO. 2021-5186
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 08/18/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF YATES INDEX NO.: 2021-5186
RMP Technik, Inc., d/b/a PENN YAN AERO,
Plaintiff,
-against-
Falcon Flying Club and Andrew Anderson,
Defendants.
NOTICE OF APPEARANCE & DEMAND FOR COMPLAINT
RACHEL LEE DREHER, ESQ.
Attorney for the Defendants
631 Lucerne Avenue
Suite 53
Lake Worth Beach, FL 33460
561.801.8661
rachel@dreherlawgroup.com
Pursuant to 22 NYCR 130-1.1, the undersigned, an attorney admitted to practice in the courts of New
York State, certifies that, upon information and belief and reasonable inquiry, the contentions
contained in the annexed document are not frivolous.
Dated: August 18, 2021 Signature: _________________________________
Rachel Lee Dreher
3 of 3
Document Filed Date
August 18, 2021
Case Filing Date
July 23, 2021
Category
Commercial - Contract
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Preview
FILED: YATES COUNTY CLERK 08/18/2021 12:41 PM INDEX NO. 2021-5186 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 08/18/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF YATES INDEX NO.: 2021-5186 X RMP Technik, Inc., d/b/a PENN YAN AERO, Plaintiff, NOTICE OF APPEARANCE -against- & DEMAND FOR COMPLAINT Falcon Flying Club and Andrew Anderson, Defendants. X PLEASE TAKE NOTICE that the undersigned has been retained as counsel of record for Defendants, FALCON FLYING CLUB and ANDREW ANDERSON and hereby appear in this action on behalf of the Defendants. Defendants hereby demand, in accordance with CPLR § 3012(b), that you serve a copy of the complaint and all notices and other previously filed papers in this action personally upon all the Defendants named in this action, in accordance with CPLR §308 at the addresses stated below. Falcon Flying Club Andrew Anderson 152 Brittany Lane 7 Falcon Drive Senoia, Georgia 30276 Peachtree City, Georgia 30269 Dated: August 18, 2021 __________________________ Rachel Lee Dreher, Esq. Attorney for the Defendants 631 Lucerne Avenue, Suite 53 Lake Worth Beach, FL 33460 561.801.8661 rachel@dreherlawgroup.com TO: KMA Zuckert LLC Eugene Massamillo, Esq. 1350 Broadway, Suite 2410 New York, NY 10018 1 of 3 FILED: YATES COUNTY CLERK 08/18/2021 12:41 PM INDEX NO. 2021-5186 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 08/18/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF YATES INDEX NO.: 2021-5186 X RMP Technik, Inc., d/b/a PENN YAN AERO, Plaintiff, CERTIFICATE OF SERVICE -against- Falcon Flying Club and Andrew Anderson, Defendants. X This is to certify that I am a member in good standing of the Bar of this Court and that on August 18, 2021; I served a copy of Defendants’ Notice of Appearance and Demand for Complaint by e-filing the demand through the New York State e-filing portal and service was completed through the e-filing system upon all parties in this action. Dated: August 18, 2021 __________________________ Rachel Lee Dreher, Esq. Attorney for the Defendants 631 Lucerne Avenue, Suite 53 Lake Worth Beach, FL 33460 561.801.8661 rachel@dreherlawgroup.com 2 of 3 FILED: YATES COUNTY CLERK 08/18/2021 12:41 PM INDEX NO. 2021-5186 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 08/18/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF YATES INDEX NO.: 2021-5186 RMP Technik, Inc., d/b/a PENN YAN AERO, Plaintiff, -against- Falcon Flying Club and Andrew Anderson, Defendants. NOTICE OF APPEARANCE & DEMAND FOR COMPLAINT RACHEL LEE DREHER, ESQ. Attorney for the Defendants 631 Lucerne Avenue Suite 53 Lake Worth Beach, FL 33460 561.801.8661 rachel@dreherlawgroup.com Pursuant to 22 NYCR 130-1.1, the undersigned, an attorney admitted to practice in the courts of New York State, certifies that, upon information and belief and reasonable inquiry, the contentions contained in the annexed document are not frivolous. Dated: August 18, 2021 Signature: _________________________________ Rachel Lee Dreher 3 of 3