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Frank J. Monteleone v. Mondo Pallon et al

Docket 650050/2021, New York State, New York County, Supreme Court (Jan. 5, 2021)
Case TypeCommercial - Contract
TagsCommercial, Civil, Contract
Plaintiff - Petitioner Frank J. Monteleone Attorney at Law
Defendant - Respondent Mondo Pallon
Defendant - Respondent Finish Systems International, LLC
...
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COMPLAINT

Document Frank J. Monteleone v. Mondo Pallon et al, 650050/2021, 2 (N.Y. Sup. Ct., New York County Jan. 5, 2021)
Upon further information and belief, Smartwood is the successor in interest to Tectonic Flooring U.S.A. LLC, a domestic limited liability company formed under the laws of the State of New York, and dissolved on or about May 4, 2017.
Pursuant to an engagement letter dated September 9, 2015, defendants retained Plaintiff to represent them in an action filed in the Supreme Court of the State of New York, County of New York titled Rupert Dowd, on his own behalf and derivatively on behalf of Tectonic Flooring U.S.A., LLC v. Mondo Pallon and Finish Systems International, LLC, Index No. 653044/2015 (Hon.
In accordance with the Agreement, Plaintiff provided legal services to Defendants as agreed from approximately August 2015 until March 15, 2017 when the aforementioned lawsuit was settled and a stipulation of discontinuance with prejudice was filed.
Plaintiff rendered ten statements of account reflecting payments and the outstanding receivable from May 1, 2017 through September 30, 2020, copies of which are annexed hereto as Exhibit D. 13.
At no time have Defendants ever denied or otherwise objected to any invoice or statement of account, but have refused to pay the remaining balance of $12,951.29, despite due demand therefore.
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AFFIRMATION/AFFIDAVIT OF SERVICE

Document Frank J. Monteleone v. Mondo Pallon et al, 650050/2021, 9 (N.Y. Sup. Ct., New York County Feb. 5, 2021)
I am over 18 years of age, not a party NAILYNN DE LA CRUZ being duly sworn, deposes and says; to this action, and reside in the State.of New York.
, - TIFFAtW--MiuPSON Notary Public, State of New York NO. 0lTH6368449 Qualified in KINGS COUNTY Commission Expires 12/11/2021 .
33 West 19th Street 4th Floor New York, NY 10011 Received by PM LEGAL LLC on the 7th day of January, 2021 at 9:00 am to be served on MONDO PALLON, 6400
1, Lourdes Vasallo, being duly sworn, depose and say that on the11th day of January, 2021 at 4:35 pm, I: SUBSTITUTE served by delivering a true copy of the SUMMONS, VERIFIED COMPLAINT WITH EXHIBITS and NOTICE OF ELECTRONIC FILING with the date and hour of service endorsed thereon by me, to: RACHEL BAERGA as CO-RESIDENT at the address of: 6400 DOLPHIN DRIVE, CORAL GABLES, FL 33158, the within named person's usual place of Abode, who resides therein, who is fifteen (15) years of age or older and informed said person of the contents therein, in compliance with state statutes.
Description of Person Served: Age: 35, Sex: F, Race/Skin Color: WHITE, Height: 5'4", Weight: 130, Hair: BLACK, Glasses: N AFFIDAVIT OF SERVICE For 650050/2021 I certify that I am over the age of 18, have no interest in the above action, and I am a Certified Process Server, appointed by the Chief Judge, in good standing, in the Eleventh Judicial Circuit of Florida, in which the process was served.
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AFFIRMATION/AFFIDAVIT OF SERVICE

Document Frank J. Monteleone v. Mondo Pallon et al, 650050/2021, 7 (N.Y. Sup. Ct., New York County Jan. 21, 2021)
on SMARTWOOD I, Lourdes Vasallo, being duly sworn, depose and say that on the 11th day of January, 2021 at 4:35 pm, 1: a LIMITED Served
therein, Said documents were conformed with index number and date of filing endorsed thereon.
of Person Served: Age: 35, Sex: F, Race/Skin Color: WHITE, Height: 5'4", Weight: 130, Hair: BLACK,
For 650050/2021 I certify „„ii that "b the age of 18, have no inte I am over ' d' od of Flond u tcial Circutt in the Eleventh h ChifJcl,i in good standing,
days after the service is complete if this summons is not personally delivered to you within the State of New York); and, in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint.
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STATEMENT OF AUTHORIZATION FOR ELECTRONIC FILING

Document Frank J. Monteleone v. Mondo Pallon et al, 650050/2021, 8 (N.Y. Sup. Ct., New York County Jan. 21, 2021)
I hereby acknowledge ("the as an authorized has registered user filing agent")
Z lZ W 87 Registration No. the law firm/agency for American that agent of or departinent Clerical Service the New York State Courts ).
Further, Irepresent authorize hereby matter in which the Uniform Rules ), ("the the they for filing
This authorization, are counsel these attorneys of record, agent the filing on behalf of these have to consented agent to record these documents posted be shall attorneys.
Resource revokes the authorization in writing Dated: ApÄ Signature fr Vk Print Name Å d/lovuÒtf roñ 4 • MocÃ-eÂ
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5

Document Frank J. Monteleone v. Mondo Pallon et al, 650050/2021, 5 (N.Y. Sup. Ct., New York County Jan. 5, 2021)

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1

Document Frank J. Monteleone v. Mondo Pallon et al, 650050/2021, 1 (N.Y. Sup. Ct., New York County Jan. 5, 2021)

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4

Document Frank J. Monteleone v. Mondo Pallon et al, 650050/2021, 4 (N.Y. Sup. Ct., New York County Jan. 5, 2021)

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