On November 30, 2018 a
Complaint,Petition
was filed
involving a dispute between
Euler Hermes North America Insurance Company As Assignees Of Gulick Freight Service Logistics Inc.,
and
Exclusive Group Inc.,
for Other Matters - Contract - Other
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 11/30/2018 12:24 PM INDEX NO. 524097/2018
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/30/2018
SUPREME COURT OF THE STATE OF NEW YORK COURT INDEX NO:
COUNTY OF KINGS SUMMONS
EULER HERMES NORTH AMERICA INSURANCE COMPANY AS FILE NO: 261927
ASSIGNEES OF GULICK FREIGHT SERVICE LOGISTICS, INC.
PLAINTIFF'S ADDRESS:
PLAINTIFF(S) 8614 NE 55TH AVE BLDG C
VANCOUVER WA 98665
-AGAINST-
EXCLUSIVE GROUP INC.
DEFENDANT'S ADDRESS:
1775 E 13TH ST #3E
BROOKLYN NY 11229
DEFENDANT(S)
The basis of the venue is : CPLR 509 CCA S305 (B)
PLANTIFF RESIDE IN THE COUNTY OUT-OF-TOWN
TO THE ABOVE NAMED DEFENDANT(S):
YOUAREHEREBYSUMMONED
To answer the complaint in this action and to serve a copy of your answer on Plaintiff's attorney's within the
time provided by law as noted below.
Upon your failure to answer, judgment will be taken against you for the sum of $41250.00 with interest there
on from 07/26/2017 together with costs of this action.
Dated: 11/28/2018 MEYÉRS SAXON & COLE
ATT N YS FOR PLAINTIFF
362 U TTN ROAD
BR KLYN, NY 11234
718-339-3330
BY:4RWilWUtEYERS/ROBERT SAXON
NOTE: The law provides that:
(a) If this summons is served by its delivery to you personally within the STATE OF NEW YORK you must
appear and answer with TWENTY days after such service; or
If this summons is served to person other than you personally or is served outside the
(b) by delivery any
STATE OF NEW YORK or or means other than personal to you within the STATE OF
publication, by any delivery
NEW YORK you are allowed THIRTY days after PROOF OF SERVICE IS FILED WITH THE CLERK OF THIS COURT
WITHIN WHICH TO APPEAR AND ANSWER.
1 of 3
FILED: KINGS COUNTY CLERK 11/30/2018 12:24 PM INDEX NO. 524097/2018
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/30/2018
SUPREME COURT OF THE STATE OF NEW YORK COURT INDEX NO:
COUNTY OF KINGS
FILE NO: 261927
EULER HERMES NORTH AMERICA INSURANCE COMPANY AS
ASSIGNEES OF GULICK FREIGHT SERVICE LOGISTICS, INC.
PLAINTlFF VERIFIED COMPLAINT
AGAINST
EXCLUSlVE GROUP INC.
DEFENDANT(S)
Plaintiff, by its attorney, complaining of the defendant(s), respectfully alleges:
1. Plaintiff IS A CORPORATION
2. That the defendant(s) resides in the county in which this action is brought; or that the defendant(s)
transacted business within the county in which this action is brought in person or through his agent and that
the instant cause of action arose out of said transaction.
3. That defendant(s) on or about 07/26/2017 entered into an agreement Goods sold delivered work labor
services rental in the agreed and specific amount of $41250.00
4. Upon information and belief, defendant(s) defaulted under the terms of the agreement by failing to make
the payments & there is due a balance in the specific sum of $41250.00.
THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
WHEREFORE, plaintiff demands judgment against defendant(s) for the sum of $41250.00 with interest from
07/26/2017 together with costs and disbursements.
ME ERS XON & COLE
A ORNE FOR PLAINTIFF
3620 QUENTIN ROAD
BROOKLYN, NY 11234
718-339-3330
2 of 3
FILED: KINGS COUNTY CLERK 11/30/2018 12:24 PM INDEX NO. 524097/2018
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/30/2018
STATE OF NEW YORK, COUNTY OF KINGS:
The undersigned, an attorney admitted to practice in the State of New York, associated with the attorneys for
the plaintiff, under penalties of perjury, affirms the following to be true. Deponent has read the foregoing
Complaint and knows the contents thereof; the same is true to deponent's own knowledge, except as to the
matters therein stated to be alleged on information and belief, and as to those matters deponent believes it to
be true; and the reason this verification is made by deponent and not by the plaintiff is because the plaintiff is
not within the county where your deponent has his office. The
grounds of deponent's belief as to all matters not stated upon deponent's knowledge are communications with
officers of the plaintiff and copies of plaintiff's records in deponent's possession.
Dated: 11/28/2018 MEYERŠÈ XON & COLE
BY: L /ROBERT SAXON
3 of 3
Document Filed Date
November 30, 2018
Case Filing Date
November 30, 2018
Category
Other Matters - Contract - Other
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FILED: KINGS COUNTY CLERK 11/30/2018 12:24 PM INDEX NO. 524097/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/30/2018 SUPREME COURT OF THE STATE OF NEW YORK COURT INDEX NO: COUNTY OF KINGS SUMMONS EULER HERMES NORTH AMERICA INSURANCE COMPANY AS FILE NO: 261927 ASSIGNEES OF GULICK FREIGHT SERVICE LOGISTICS, INC. PLAINTIFF'S ADDRESS: PLAINTIFF(S) 8614 NE 55TH AVE BLDG C VANCOUVER WA 98665 -AGAINST- EXCLUSIVE GROUP INC. DEFENDANT'S ADDRESS: 1775 E 13TH ST #3E BROOKLYN NY 11229 DEFENDANT(S) The basis of the venue is : CPLR 509 CCA S305 (B) PLANTIFF RESIDE IN THE COUNTY OUT-OF-TOWN TO THE ABOVE NAMED DEFENDANT(S): YOUAREHEREBYSUMMONED To answer the complaint in this action and to serve a copy of your answer on Plaintiff's attorney's within the time provided by law as noted below. Upon your failure to answer, judgment will be taken against you for the sum of $41250.00 with interest there on from 07/26/2017 together with costs of this action. Dated: 11/28/2018 MEYÉRS SAXON & COLE ATT N YS FOR PLAINTIFF 362 U TTN ROAD BR KLYN, NY 11234 718-339-3330 BY:4RWilWUtEYERS/ROBERT SAXON NOTE: The law provides that: (a) If this summons is served by its delivery to you personally within the STATE OF NEW YORK you must appear and answer with TWENTY days after such service; or If this summons is served to person other than you personally or is served outside the (b) by delivery any STATE OF NEW YORK or or means other than personal to you within the STATE OF publication, by any delivery NEW YORK you are allowed THIRTY days after PROOF OF SERVICE IS FILED WITH THE CLERK OF THIS COURT WITHIN WHICH TO APPEAR AND ANSWER. 1 of 3 FILED: KINGS COUNTY CLERK 11/30/2018 12:24 PM INDEX NO. 524097/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/30/2018 SUPREME COURT OF THE STATE OF NEW YORK COURT INDEX NO: COUNTY OF KINGS FILE NO: 261927 EULER HERMES NORTH AMERICA INSURANCE COMPANY AS ASSIGNEES OF GULICK FREIGHT SERVICE LOGISTICS, INC. PLAINTlFF VERIFIED COMPLAINT AGAINST EXCLUSlVE GROUP INC. DEFENDANT(S) Plaintiff, by its attorney, complaining of the defendant(s), respectfully alleges: 1. Plaintiff IS A CORPORATION 2. That the defendant(s) resides in the county in which this action is brought; or that the defendant(s) transacted business within the county in which this action is brought in person or through his agent and that the instant cause of action arose out of said transaction. 3. That defendant(s) on or about 07/26/2017 entered into an agreement Goods sold delivered work labor services rental in the agreed and specific amount of $41250.00 4. Upon information and belief, defendant(s) defaulted under the terms of the agreement by failing to make the payments & there is due a balance in the specific sum of $41250.00. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. WHEREFORE, plaintiff demands judgment against defendant(s) for the sum of $41250.00 with interest from 07/26/2017 together with costs and disbursements. ME ERS XON & COLE A ORNE FOR PLAINTIFF 3620 QUENTIN ROAD BROOKLYN, NY 11234 718-339-3330 2 of 3 FILED: KINGS COUNTY CLERK 11/30/2018 12:24 PM INDEX NO. 524097/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/30/2018 STATE OF NEW YORK, COUNTY OF KINGS: The undersigned, an attorney admitted to practice in the State of New York, associated with the attorneys for the plaintiff, under penalties of perjury, affirms the following to be true. Deponent has read the foregoing Complaint and knows the contents thereof; the same is true to deponent's own knowledge, except as to the matters therein stated to be alleged on information and belief, and as to those matters deponent believes it to be true; and the reason this verification is made by deponent and not by the plaintiff is because the plaintiff is not within the county where your deponent has his office. The grounds of deponent's belief as to all matters not stated upon deponent's knowledge are communications with officers of the plaintiff and copies of plaintiff's records in deponent's possession. Dated: 11/28/2018 MEYERŠÈ XON & COLE BY: L /ROBERT SAXON 3 of 3