Motion for Writ in Chirag Patel v. Frank F Ozpolat, Arzu F Ozpolat, European American Waste Disposal Corp., a/k/a EUROPEAN-AMERICAN WASTE DISPOSAL CORP., a New York Corporation, European American Waste Services Inc., A New York Corporation, Gemini Property Acquisitions, Llc, a/k/a GEMINI PROP ACQUISITIONS, LLC, a New York Limited Liability Company, Emrah Artukmac| Trellis.Law

On June 05, 2024 a Summons was filed involving a dispute between Chirag Patel, and Arzu F Ozpolat, Emrah Artukmac, European American Waste Disposal Corp., A K A European-American Waste Disposal Corp., A New York Corporation, European American Waste Services Inc., A New York Corporation, Frank F Ozpolat, Gemini Property Acquisitions, Llc, A K A Gemini Prop Acquisitions, Llc, A New York Limited Liability Company, for Torts - Other (Fraudulent Inducement) in the District Court of Nassau County.

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
-----------------------------------------------------------------x
CHIRAG PATEL, Index No.:

Plaintiff, SUMMONS

-against-

FRANK F. OZPOLAT;
ARZU F. OZPOLAT;
EUROPEAN AMERICAN WASTE DISPOSAL CORP.,
a/k/a EUROPEAN-AMERICAN WASTE DISPOSAL
CORP., a New York Corporation;
EUROPEAN AMERICAN WASTE SERVICES INC.,
a New York Corporation;
GEMINI PROPERTY ACQUISITIONS, LLC, a/k/a
GEMINI PROP ACQUISITIONS, LLC, a New York
Limited Liability Company;
EMRAH ARTUKMAÇ; AND
DOES 1 THROUGH 5 inclusive,

Defendants.
------------------------------------------------------------------x

To the above-named defendants:

You are hereby summoned and required to serve upon Plaintiff’s attorney an answer to

the complaint in this action within 20 days after the service of this summons, exclusive of the

day of service, or within 30 days after service is complete if this summons is not personally

delivered to you within the State of New York. In case of your failure to answer, judgment will

be taken against you by default for the relief demanded in the complaint.

The basis of the venue designated is the residence of Plaintiff and some of the defendants

and the county in which a substantial part of the events or omissions giving rise to the claims

occurred. The place of trial is Nassau County Supreme Court, 100 Supreme Court Drive,

Mineola, New York 11501.

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Dated: June 4, 2024 Respectfully submitted,

s/ Carolyn Shields

Carolyn Shields
Ying Liu
Liu & Shields LLP
Attorney for Plaintiff CHIRAG PATEL
41-60 Main Street, Suite 208A
Flushing, NY 11355
Tel: 718-463-1868
Direct: 347-840-1600
Email: shieldscj524@gmail.com

To:

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
-----------------------------------------------------------------x
CHIRAG PATEL, Index No.:

Plaintiff, COMPLAINT

-against-

FRANK F. OZPOLAT;
ARZU F. OZPOLAT;
EUROPEAN AMERICAN WASTE DISPOSAL CORP.,
a/k/a EUROPEAN-AMERICAN WASTE DISPOSAL
CORP., a New York Corporation;
EUROPEAN AMERICAN WASTE SERVICES INC.,
a New York Corporation;
GEMINI PROPERTY ACQUISITIONS, LLC a/k/a
GEMINI PROP ACQUISITIONS, LLC, a New York
Limited Liability Company;
EMRAH ARTUKMAÇ; AND
DOES 1 THROUGH 5 inclusive,

Defendants.
------------------------------------------------------------------x

Plaintiff Chirag Patel (hereinafter “Plaintiff” or “Buyer”), for his complaint against

FRANK F. OZPOLAT; ARZU F. OZPOLAT; EUROPEAN AMERICAN WASTE DISPOSAL

CORP., a/k/a EUROPEAN-AMERICAN WASTE DISPOSAL CORP., a New York Corporation

(referred to individually as “Disposal”); EUROPEAN AMERICAN WASTE SERVICES INC., a

New York Corporation (referred to individually as “Services”); (the four defendants Frank F.

Ozpolat, Arzu F. Ozpolat, Disposal, and Services are referred to collectively as “Sellers” or

“Seller Defendants”); GEMINI PROPERTY ACQUISITIONS, LLC a/k/a GEMINI PROP

ACQUISITIONS, LLC (referred to individually as “Gemini”); EMRAH ARTUKMAÇ (referred

to individually as “Escrow Defendant”); and DOES 1 THROUGH 5 inclusive, alleges the

following:

1. Buyer is a resident of Nassau County, State of New York.

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2. Upon information and belief defendants FRANK F. OZPOLAT and ARZU F.

OZPOLAT are residents of Nassau County, State of New York, and reside at 1679 Hannington

Avenue, Wantagh, Nassau County, State of New York 11793.

3. Defendant Frank F. Ozpolat is the president of Disposal, the president of Services,

and the Chief Executive Officer of Gemini.

4. Defendants Frank F. Ozpolat and Arzu F. Ozpolat are shareholders in the

defendants Disposal and Services.

5. Defendant Disposal is a corporation formed under the laws of the State of New

York and has its principal office in Nassau County, State of New York at 1800 Roland Avenue,

Wantagh, New York 11793.

6. Defendant Services is a corporation formed under the laws of the State of New

York and has its principal office in Nassau County, State of New York at 989 McLean Avenue,

Wantagh, New York 11793 or at 1800 Roland Avenue, Wantagh, New York 11793.

7. Defendant GEMINI is a limited liability company formed under the Limited

Liability Company Law of the State of New York and has its principal office at 1800 Roland

Avenue, Wantagh, New York 11793.

8. Defendant EMRAH ARTUKMAÇ maintains an office for the practice of law at

258 Hawkins Avenue, Ronkonkoma, Suffolk County, State of New York 11779 and upon

information and belief resides in Suffolk County, State of New York, at 210 Barnum Avenue,

Port Jefferson, New York 11777.

9. The identities of defendants sued under the fictitious names Does 1 Through 5

Inclusive are at present unknown to plaintiff and are liable in whole or in part for the causes of

action alleged herein. When plaintiff discovers the identities of said fictitious defendants and the

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facts supporting their liability for the causes of action alleged herein, plaintiff will seek leave to

amend his complaint.

10. Venue in this county is proper under CPLR 503(a), (c), and (d).

FACTUAL ALLEGATIONS

11. This action arises out of a negotiation for the purchase by Buyer of the waste

management business of the Seller Defendants through the purchase of stock, resulting in two

signed documents (“Writings”) attempting to effect the sale through the sale of stock of the

Seller Defendants. Attached as Exhibits A and B and incorporated herein with all of their terms

are the two signed Writings, Exhibit A being for the purchase of Disposal, Exhibit B being for

the purchase of Services.

12. The Writings identify the Seller Defendants—FRANK F. OZPOLAT; ARZU F.

OZPOLAT; Disposal, and Services—as the sellers.

13. On September 13, 2023, Buyer delivered the down payment of $300,000 called

for by paragraph 1.1(a) of the Writing with FRANK F. OZPOLAT; ARZU F. OZPOLAT; and

Services (see Exhibit B) to the Seller Defendants’ attorney, the Escrow Defendant, to be held in

escrow pending the satisfaction of the terms required for closing. On September 21, 2023, the

Escrow Defendant, Sellers’ attorney, acknowledged in writing along with delivery of the

Writings signed by the Sellers to the Buyer’s transactional attorney that he and his firm were

holding the down payment in escrow, stating: “Your client’s [plaintiff’s] down payment of

$300,000.00 is being held in our firm's escrow account at Chase Bank, N.A.”

14. The Writings, though signed by both Buyer and Sellers, were defective,

incomplete, misleading, and, with respect to material terms, in breach and with intentional

misrepresentations. As a result and pursuant to the terms of the Writings and applicable law,

Buyer demanded on or about April 18, 2024 the return of his down payment.

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15. Sellers and their attorney, the Escrow Defendant, failed to return Buyer’s down

payment despite the explanation of the grounds for its return by Buyer’s undersigned attorneys,

necessitating this lawsuit.

16. The Escrow Defendant’s failure to return Buyer’s down payment is a breach of his

obligations under the law, under the Writings, and under section 487 of the New York Judicial

Law, which imposes treble damages on him for failing to return the downpayment. The Seller

Defendants are also liable to Buyer for the failure of their attorney and agent to return the down

payment under circumstances that required them to do so, entitling Buyer to the recovery of his

down payment and damages.

17. This complaint sets forth the defects, misrepresentations, and breaches by Sellers

that justify the return of Buyer’s down payment and his right to damages and other relief.

Corporate Misrepresentations

18. The Disposal and Services corporations are not in good standing. The last

biennial reports for both corporations were filed in 2016, and the corporations owe reports for

2018, 2020, 2022, and, depending, 2024.

19. The Writings (Exhibit A) proposed to sell 200 shares of Disposal. But there are

only 100 authorized shares of Disposal, so Sellers cannot sell 200 shares of Disposal.

20. The Writings (Exhibit B) proposed to sell 200 shares of Services. But there are

10,000 authorized shares of Services and Sellers did not disclose whether any of the 9,800 shares

of Services were issued and if so to whom. This would be easier to see if the Writings had

attached the corporate information to Schedule 3.1 as promised by Sellers in the Writings.

The Writings Are Incomplete and Contain Material Misrepresentations

21. The Writings (Exhibits A and B) are required to, but did not, identify with

reasonable certainty the essential terms of the Sellers’ promises and are incomplete.

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22. No documents are attached to the schedules in the Writings, including but not

limited to Schedule 3.3 (Liabilities) and Schedule 3.10 (Litigations). It follows that the Sellers’

representations (Exhibits A and B: “3.3 Liabilities. Except as set forth on Schedule 3.3,

Seller and the Company have no other Liabilities.”; Exhibits A and B: “3.10 Litigation;

Compliance with Laws. Except as set forth on Schedule 3.10 there is no litigation,

arbitration or other proceeding or governmental investigation pending or, to the Seller’s

knowledge, threatened, or any order outstanding against or relating to Seller, the

Company, or the Equity Interest”) that there are no liabilities except as shown in Schedule 3.3

and that there are no litigations except as shown in Schedule 3.10 are representations that there

are no liabilities and no litigations.

23. Contrary to Sellers’ representations that there are no liabilities, Buyer’s

investigation discovered that there are. There are unterminated UCC filings by at least six

creditors claiming Article 9 security interests in the assets of Disposal and Services, making

Sellers’ representations to the contrary false representations.

24. Contrary to Sellers’ representations that there are no Litigations (Exhibits A and B

para. 3.10 and para. 22 above), Buyer’s investigation discovered that there is pending litigation,

making Sellers’ representation (Exhibits A and B, para. 3.10) that there is no litigation other than

that shown in Schedule 3.10, which shows no litigation, a false representation. Buyer’s

investigation shows a Fair Labor Standards Act class action lawsuit filed against Services and

Frank Ozpolat in the United States District Court for the Eastern District of New York, Case

Number 2:24-cv-01216. There is not usually insurance that provides a defense or indemnity in

such cases, and the projected expense of an uninsured defense and indemnity in such a case,

which is usually high given liquidated damages, liability for plaintiffs’ attorney’s fees, and a high

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applicable interest rate, should have reduced the purchase price under paragraph 1.1 of the

Writings.

25. There are approximately four personal injury motor vehicle lawsuits against one

or the other of the corporate Sellers, depending on which owned the offending vehicle. The

Sellers should have liability insurance covering the defense and indemnity of these cases, but

should have disclosed to Buyer the contingent liabilities for uncovered claims, as well as the

Sellers’ liability for a cross-claim asserted by the County of Suffolk.

26. Schedule 3.14 in the Writings requires attachment of the Sellers’ tax returns but

no tax returns are attached.

27. Sellers’ failure to disclose liabilities and contingent liabilities also is a breach of

paragraph 1.1, which represents that the purchase prices has been reduced by or credited with the

liabilities shown in Schedule 3.3, which is no reduction and no credit. The Writings’ failure to

disclose a required reduction in the purchase price fraudulently induced Buyer to sign them, the

effect of which was that Sellers passed on their liabilities to the prospective new owner.

28. In the case of the purchase of a business through the purchase of stock, and given

that the Buyer stands in the shoes of the corporation whose stock is purchased, it is essential

terms that disclose liabilities and litigations and the financial condition of the seller. Sellers’

failure to disclose this information is a material misrepresentation.

29. The foregoing constitute fraudulent inducements to Buyer to sign the Writings,

entitling Buyer to terminate the deal and recover his downpayment and damages.

30. The foregoing make the Writings incomplete and execution of them was not a

“complete execution” of a contract.

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31. Because the Writings were incomplete, there was not complete execution of them,

and the term of the Second Rider, paragraph 2R1, that affords the buyer 30 days after “complete

execution of the Share Purchase Agreement” never began to run.

32. The Writings were subject to unsatisfied conditions precedent that prevented any

obligation of the Buyer from arising. These include the condition that the proceedings and

documents be satisfactory to the Buyer and his attorneys (Exhibit A, para. 5.7; Exhibit B, para.

5.8). On April 18, 2024, the Buyer’s undersigned attorneys wrote to Sellers’ attorney identifying

the proceedings and documents that were unsatisfactory and explaining the reasons.

33. Any actions by defendants to insert documents to attempt to cure the

incompleteness of the Writings after execution of them by the Buyer would be an alteration, an

“unauthorized insertion in a blank space in a writing” that discharges the Buyer and entitles the

Buyer to restitution of his downpayment.

Lease

34. Among the assets of the Sellers that would have accompanied the purchase of

Sellers’ stock are a lease of real property in Suffolk County, in the Hamlet of Ronkonkoma,

Town of Islip, at 1000 10th Street, Ronkonkoma, New York, being known as District 500, Section

105, Block 2, Lots 133.1, 134, 135, 139.1, 140.1. This real property was an essential part of the

business in that it provided space for the businesses’ trucks. The leased property was owned by

an affiliated limited liability company, defendant Gemini, a member of whom is defendant Frank

F. Ozpolat.

35. Sellers wholly failed to deliver to Buyer a signed lease or assignment of lease that

would deliver this asset of Sellers to Buyer.

36. Sellers did deliver to Buyer an unsigned lease to the real property which Sellers

had prepared in the name of the property owner, defendant Gemini and which, when combined

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with the Writings attached as Exhibits A and B, show that the unsigned lease arose out of the

same transaction as the Exhibit A and B Writings and was essential to the businesses to be sold

under the Exhibit A and B Writings. A true and correct copy of the Lease is attached as Exhibit

C and incorporated herein with all of its terms.

37. The connection between the Lease and the Writings is evident from paragraph

2.01 of the Lease which provides that “the Tenant will use the Demised Premises solely for the

storage of not more than seventeen (17) commercial refuse trucks and the placement of an office

trailer as designated in the annexed Exhibit ‘A’, subject to the prior written approval of the

Landlord in its sole discretion, and for no other purpose whatsoever.”

38. The connection between the Lease and the Writings is also evident from

paragraph 5.03 of the Lease, which requires a personal guaranty from Chirag N. Patel, identified

in the Lease as principal of the Tenant, who is the named Buyer of the businesses in the Writings.

Further, it is evident from Sellers’ oral representations that garbage trucks would be among the

assets to be sold that a place to put the trucks involved in the businesses was essential.

39. The foregoing connections between the Lease and the Writings is established by

references in them to the same subject matter or transaction, requiring them to be read together.

40. Sellers breached their obligations to the Buyer by failing to provide a signed copy

of the Lease to Buyer, another aspect of the deal that was incomplete and fraudulent.

41. The foregoing connections between the Lease and the Writings entitle Plaintiff to

a declaration that Plaintiff is entitled to possession of the premises that are the subject of the

Lease.

FIRST CAUSE OF ACTION
(Fraudulent Inducement Against Seller Defendants and Doe Defendants)

42. Plaintiff incorporates paragraphs 1 through 41 of this complaint.

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43. The foregoing allegations show that the Seller Defendants and Doe Defendants

made false representations of material facts to Buyer.

44. The false representations of material facts made by the Seller Defendants and Doe

Defendants to Buyer were known to them to be untrue, as shown in part by Seller Defendants’

and Doe Defendants’ withholding of information about Sellers’ financial condition, liabilities,

and litigation from Buyer.

45. The false representations of material facts made by the Seller Defendants and Doe

Defendants were made with the intention of inducing reliance and forbearance from further

inquiry by Buyer, as shown in part by the refusal of Seller Defendants and Doe Defendants to

recognize that Buyer was entitled to the due diligence period provided by the Writings.

46. Buyer justifiably relied upon the false representations of Seller Defendants and

Doe Defendants.

47. As a result of the foregoing, Buyer was damaged through delivering a down

payment of $300,000 and his investment in investigating and acquiring a business he intended to

acquire.

48. The conduct of Seller Defendants and Doe Defendants was willful, malicious, and

undertaken with conscious disregard for the rights of Plaintiff, entitling Plaintiff to an award of

punitive damages.

SECOND CAUSE OF ACTION
(Intentional Misrepresentation Against Seller Defendants and Doe Defendants)

49. Plaintiff incorporates the allegations of paragraphs 1 through 48 of this complaint.

50. As alleged herein, the Seller Defendants and Doe Defendants made

misrepresentations and material omissions of facts to Buyer.

51. Seller Defendants’ and Doe Defendants’ misrepresentations and material

omissions of fact were false and known to be false by Seller Defendants and Doe Defendants

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when made.

52. Seller Defendants’ and Doe Defendants’ misrepresentations and material

omissions of fact were made for the purpose of inducing Plaintiff to rely upon them.

53. Plaintiff justifiably relied on Seller Defendants’ and Doe Defendants’

misrepresentations and material omissions to his detriment.

54. The foregoing caused Plaintiff injury, for which he seeks damages putting him in

the position he was in status quo ante.

55. The conduct of Seller Defendants and Doe Defendants was willful, malicious, and

undertaken with a conscious disregard for the rights of Plaintiff, entitling Plaintiff to an award of

punitive damages.

THIRD CAUSE OF ACTION
(Breach of Contract Against Seller Defendants)

56. Plaintiff incorporates the allegations of paragraphs1 through 55 of this complaint.

57. Although Plaintiff denies that a contract between him and the Seller Defendants

was formed, if a contract is determined to have been formed, Seller Defendants breached it

through the conduct alleged herein, including but not limited to warranting that Seller

Defendants had no liabilities and no litigations when they did, and refusing to comply with

paragraph 2R1 of the Second Rider granting Plaintiff a period of time for his due diligence that

had not begun to run, by refusing to return or direct the return of Plaintiff’s down payment, and,

if Plaintiff’s down payment is no longer being held in escrow by Sellers’ attorney, by breaching

the terms under which holding the down payment in escrow may be terminated.

58. Sellers’ breach of contract entitles Plaintiff to recover damages that will put him

in the position he would have been in if Seller Defendants had performed their obligations under

the contract together with restitution of Plaintiffs’ down payment.

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FOURTH CAUSE OF ACTION
(Unjust Enrichment and Restitution Against All Defendants)

58. Plaintiff incorporates the allegations of paragraphs 1 through 57 of this complaint.

59. Defendants were unjustly enriched at the expense of Plaintiff through the conduct

alleged herein.

60. It is against equity and good conscience to permit Defendants to retain the down

payment which Plaintiff seeks to recover and other benefits by which Defendants were enriched.

61. As a remedy for Defendants’ unjust enrichment, Defendants are required to return

Plaintiff’s down payment to him and other benefits by which Defendants were enriched.

FIFTH CAUSE OF ACTION
(Failure to Return Down Payment Against the Escrow Defendant, Sellers, and Doe Defendants)

62. Plaintiff incorporates the allegations of paragraphs 1 through 61 of this complaint.

63. Paragraph 1.1(a) of the Writings called for Plaintiff to deliver $300,000 to

Defendants as a down payment toward the purchase price of Sellers’ businesses.

64. On September 13, 2023, before Seller Defendants signed the Writings, Plaintiff

delivered to the Escrow Defendant a good check in the amount of $300,000 (Three Hundred

Thousand and 00/100ths Dollars) payable to “The Law Office of EMRAH ARTUKMAÇ, P.C.,

as Attorney” as the down payment called for by paragraph 2.2(a) of the Writings.

65. The Escrow Defendant was required to and upon information and belief is holding

Plaintiff’s downpayment of $300,000 in escrow pursuant to the Writings, the agreement of the

parties, and his own written consent made to Plaintiff’s attorney on September 21, 2023 that

“Your client’s [Plaintiff’s] down payment of $300,000.00 is being held in our firm’s escrow

account at Chase Bank, N.A.”

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66. Plaintiff’s undersigned attorneys made written demand on the Escrow

Defendant on or about April 18, 2024 that he return by April 24, 2024 Plaintiff’s down payment

which he was holding in escrow.

67. The Escrow Defendant failed and continues to fail to return the down payment to

Plaintiff.

68. The Escrow Defendant is the agent of Sellers. and the Escrow Defendant, the

Sellers, and the Doe Defendants are liable to Plaintiff for the sum of $300,000.00 not returned to

Plaintiff, together with treble damages against the Escrow Defendant under section 487 of the

New York Judiciary Law.

SIXTH CAUSE OF ACTION
(Declaratory Judgment Against Defendants GEMINI, Sellers, and Frank F. Ozpolat)

69. Plaintiff incorporates the allegations of paragraphs 1 through 68 of this complaint.

70. Plaintiff seeks a declaratory judgment against defendants Gemini, Sellers, and

Frank F. Ozpolat as to the rights and other legal relations between Plaintiff and said defendants

as to the justiciable controversy between them in respect of the lease attached as Exhibit C. As

alleged herein, said dispute is real, definite, substantial, and ripe for judicial determination. See

particularly paragraphs 34 through 41 herein and the exhibits hereto.

71. Plaintiff was entitled as an incident of the purchase of the stock in Sellers’

businesses a signed lease from GEMINI for the possession of real property in Ronkonkoma,

New York, for space for garbage trucks and office space, an asset of Sellers that was a subject of

the sales.

72. Said lease from defendant Gemini was withheld by Sellers and delivered to

Plaintiff without a signature by defendant Frank F. Ozpolat on behalf of defendant Gemini.

73. Plaintiff is entitled to enforce the said Lease (Exhibit C) as connected to, and

arising out of the same transaction as, the Writings (Exhibits A and B).

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74. Plaintiff does not have an adequate remedy at law.

75. Plaintiff seeks declaratory relief against Gemini, Sellers, and Frank F. Ozpolat

declaring that Plaintiff is entitled to possession of the real property described in the Lease

attached as Exhibit C.

The damages sought herein exceed the damages recoverable in all inferior courts.

Plaintiff seeks a trial by jury of all issues triable by jury.

WHEREFORE, Plaintiff prays for the following:

ON THE FIRST CAUSE OF ACTION:

Compensatory damages according to proof sufficient to put Plaintiff in status quo ante,

together with an award of punitive damages; and

ON THE SECOND CAUSE OF ACTION:

Compensatory damages according to proof sufficient to put Plaintiff in status quo ante,

together with an award of punitive damages; and

ON THE THIRD CAUSE OF ACTION:

Compensatory damages sufficient to put Plaintiff in the position he would have been in had

Sellers performed their contract obligations, together with the return of Plaintiff’s down payment

of $300,000; and

ON THE FOURTH CAUSE OF ACTION:

An award of restitution of the benefits by which Defendants were enriched, including Plaintiff’s

down payment of $300,000; and

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ON THE FIFTH CAUSE OF ACTION:

An order and judgment requiring the Escrow Defendant, the Sellers, and the Doe Defendants to

return the sum of $300,000 to Plaintiff, together with treble damages against the Escrow

Defendant under section 487 of the New York Judiciary Law; and

ON THE SIXTH CAUSE OF ACTION:

A declaratory judgment against defendants Gemini, Sellers, and Frank F. Ozpolat declaring that

Plaintiff is entitled to possession of the real property described in the Lease attached as Exhibit C

and to a lease to the stated real property signed by defendant Gemini; and

ON ALL CAUSES OF ACTION:

Plaintiff prays for the entry of a judgment in his favor on the causes of action alleged herein,

together with Plaintiff’s reasonable attorney’s fees and costs and such other and further relief as

the Court may deem just.

June 4, 2024 Respectfully submitted,

s/ Carolyn Shields

Carolyn Shields
Liu & Shields LLP
41-60 Main Street, Suite 208A
Flushing, NY 11355
Tel: 718-463-1868
Direct: 347-840-1600
Attorneys for Plaintiff

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Case Info

Case No.

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Document Filed Date

June 05, 2024

Case Filing Date

June 05, 2024

County

Parties

Arzu F Ozpolat Defendant
Chirag Patel Plaintiff
Emrah Artukmac Defendant
EUROPEAN AMERICAN WASTE DISPOSAL CORP., a/k/a EUROPEAN-AMERICAN WASTE DISPOSAL CORP., a New York Corporation Defendant
EUROPEAN AMERICAN WASTE SERVICES INC., a New York Corporation Defendant
Frank F Ozpolat Defendant
GEMINI PROPERTY ACQUISITIONS, LLC, a/k/a GEMINI PROP ACQUISITIONS, LLC, a New York Limited Liability Company Defendant
SHIELDS, CAROLYN Attorney for the Plaintiff

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