![]() ![]() ![]() `Additionally, Guarantor is responsible for all amounts incurred as a result of any `owing by Company Defendant to Plaintiff under the Agreement. ![]() `Despite due demand, Company Defendant has failed to pay the amounts due and `Damages fee in the amount of $2,500.00, and NSF fees in the amount of $140.00. In addition, pursuant to the Agreement, Company defendant incurred a Reasonable `Company Defendant made payments totaling $20,986.00 leaving a balance of `making the agreed upon ACH withdrawals from the Bank Account while conducting regular `otherwise breached the Agreement by intentionally impeding and preventing Plaintiff from `Company Defendant, however, stopped making its payments to Plaintiff and `Plaintiff remitted the purchase price for the future receivables to Company `from Company Defendant upon a breach in performance by Company Defendant. `In addition, Guarantor agreed to guarantee any and all amounts owed to Plaintiff `to make daily ACH withdrawals until $29,980.00 was fully paid to Plaintiff. `approved by Plaintiff (the "Bank Account") from which Company Defendant authorized Plaintiff `Pursuant to the Agreement, Company Defendant agreed to have one bank account `Defendant's future receivables having an agreed upon value of $29,980.00. `agreement (the "Agreement") whereby Plaintiff agreed to purchase all rights to Company `On or about November 24, 2020, Plaintiff and Defendants entered into an `instituted in any court sitting in New York State. `individual residing in the State of Indiana who agreed that any action between the parties be `Upon information and belief, at all relevant times, Guarantor was and is a n `action between the parties be instituted in any court sitting in New York State. `is a company organized and existing under the laws of the State of Indiana that agreed that any `Upon information and belief, at all relevant times, Company Defendant was and `organized and existing under the laws of the State of New York. ![]() `At all relevant times, Plaintiff was and is a Limited Liability Company `(Company Defendant and Guarantor collectively "Defendants"), alleges as follows: `DEPLOYIT USA ("Company Defendant") and AARON VINCENT BARNES ("Guarantor") Miller Esq., for its complaint herein against DEPLOYIT USA INC D/B/A `Plaintiff Everyday Funding Group, LLC ("Plaintiff'), by a n d t h r o u g h its attorney, `The basis for venue is pursuant to the Contract entered between the parties. `demanded in the complaint, without further notice to you. `limitation stated above, a judgment may be entered against you, by default, for the relief `If you do not serve an answer to the attached complaint within the applicable time `within thirty days after service of the summons is complete as provided by law. `was not personally delivered to you within the State of New York, the answer must be served `twenty days after such service of the summons, excluding the date of service. `personally delivered upon you in the State of New York, the answer must be served within `at the address stated below, an answer to the attached complaint. `YOU ARE HEREB Y SUMMONED and required to serve upon Plaintiff attorney, ![]()
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