Preview
FILED: NEW YORK COUNTY CLERK 01/08/2024 07:38 PM INDEX NO. 650106/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/08/2024
SUMMONS
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
STANCE CAPITAL I FUND, Summons
Plaintiff,
—against—
ANTHONY STACY,
APRIL STACY,
Defendants.
To the above-named defendants:
You are hereby summoned and required to serve upon plaintiff’s attorney your answering papers
on this motion within twenty days after the service of this summons, exclusive of the day of
service, or within thirty days after service is complete if this summons is not personally delivered
to you within the State of New York. If you fail to submit answering papers, summary judgment
will be entered against you by default for the relief demanded in the Notice of Motion.
The basis of the venue designated is the place of business of the plaintiff, and as designated
within the promissory note agreed upon by all parties.
Dated: January 8, 2024
Maryam N. Hadden, Esq.
______________________
Attorney for Plaintiff
Parlatore Law Group, LLP
260 Madison Avenue, 17th Fl.
New York, New York 10016
Tel: (646)846-6382
Email: maryam.hadden@parlatorelawgroup.com
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FILED: NEW YORK COUNTY CLERK 01/08/2024 07:38 PM INDEX NO. 650106/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/08/2024
NOTICE OF MOTION
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
STANCE CAPITAL I FUND, Notice of Motion for Summary Judgment in
Lieu of Complaint
Plaintiff,
Index No. ______________________
—against—
ANTHONY STACY,
APRIL STACY,
Defendants.
PLEASE TAKE NOTICE, that upon the summons, dated January 8, 2024, and the
affidavit of Andrew J. Albano, sworn to on January 5, 2024, as well as the exhibit annexed thereto,
the plaintiff will move this court at the New York County Supreme Court, 60 Centre Street, New
York, New York, on February 13, 2024, at 9:30 A.M., or as soon thereafter as counsel can be
heard, for an order directing the entry of judgment for the plaintiff Stance Capital I Fund and
against the defendants Anthony Stacy and April Stacy in the amount of Seven Hundred Ninety-
Five Thousand Four Hundred Seventy-Three Dollars and Sixty-Seven Cents ($795,473.67), with
9% interest from August 7, 2023, plus the costs of this motion and attorney’s fees through the date
of judgment, and for such other and further relief as to the court may seem just and proper, upon
the ground that this action is based upon an instrument for the payment of money only which is
now due and payable.
PLEASE TAKE FURTHER NOTICE that pursuant to CPLR § 2214(b), all answering
papers, if any, shall be served on the undersigned no later than seven (7) days prior to the return
date of this motion.
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FILED: NEW YORK COUNTY CLERK 01/08/2024 07:38 PM INDEX NO. 650106/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/08/2024
Dated: January 8, 2024
Maryam N. Hadden, Esq.
___________________________________________
Attorney for Plaintiff
Parlatore Law Group, LLP
260 Madison Avenue, 17th Fl.
New York, New York 10016
Tel: (646)846-6382
Email: maryam.hadden@parlatorelawgroup.com
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Preview
FILED: NEW YORK COUNTY CLERK 01/08/2024 07:38 PM INDEX NO. 650106/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/08/2024 SUMMONS SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK STANCE CAPITAL I FUND, Summons Plaintiff, —against— ANTHONY STACY, APRIL STACY, Defendants. To the above-named defendants: You are hereby summoned and required to serve upon plaintiff’s attorney your answering papers on this motion within twenty days after the service of this summons, exclusive of the day of service, or within thirty days after service is complete if this summons is not personally delivered to you within the State of New York. If you fail to submit answering papers, summary judgment will be entered against you by default for the relief demanded in the Notice of Motion. The basis of the venue designated is the place of business of the plaintiff, and as designated within the promissory note agreed upon by all parties. Dated: January 8, 2024 Maryam N. Hadden, Esq. ______________________ Attorney for Plaintiff Parlatore Law Group, LLP 260 Madison Avenue, 17th Fl. New York, New York 10016 Tel: (646)846-6382 Email: maryam.hadden@parlatorelawgroup.com 1 of 3 FILED: NEW YORK COUNTY CLERK 01/08/2024 07:38 PM INDEX NO. 650106/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/08/2024 NOTICE OF MOTION SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK STANCE CAPITAL I FUND, Notice of Motion for Summary Judgment in Lieu of Complaint Plaintiff, Index No. ______________________ —against— ANTHONY STACY, APRIL STACY, Defendants. PLEASE TAKE NOTICE, that upon the summons, dated January 8, 2024, and the affidavit of Andrew J. Albano, sworn to on January 5, 2024, as well as the exhibit annexed thereto, the plaintiff will move this court at the New York County Supreme Court, 60 Centre Street, New York, New York, on February 13, 2024, at 9:30 A.M., or as soon thereafter as counsel can be heard, for an order directing the entry of judgment for the plaintiff Stance Capital I Fund and against the defendants Anthony Stacy and April Stacy in the amount of Seven Hundred Ninety- Five Thousand Four Hundred Seventy-Three Dollars and Sixty-Seven Cents ($795,473.67), with 9% interest from August 7, 2023, plus the costs of this motion and attorney’s fees through the date of judgment, and for such other and further relief as to the court may seem just and proper, upon the ground that this action is based upon an instrument for the payment of money only which is now due and payable. PLEASE TAKE FURTHER NOTICE that pursuant to CPLR § 2214(b), all answering papers, if any, shall be served on the undersigned no later than seven (7) days prior to the return date of this motion. 2 of 3 FILED: NEW YORK COUNTY CLERK 01/08/2024 07:38 PM INDEX NO. 650106/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/08/2024 Dated: January 8, 2024 Maryam N. Hadden, Esq. ___________________________________________ Attorney for Plaintiff Parlatore Law Group, LLP 260 Madison Avenue, 17th Fl. New York, New York 10016 Tel: (646)846-6382 Email: maryam.hadden@parlatorelawgroup.com 3 of 3