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efta-efta01203561DOJ Data Set 9OtherWILED: NEW YORK COUNTY CLERK 07/15/2015 12:41 Pl4
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WILED: NEW YORK COUNTY CLERK 07/15/2015 12:41 Pl4
NYSCEF DOC. NC.
INDEX NO. 652489/2015
RECEIVED NYSCEF: 07/15/2015
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
BENEDICT P. MORELLI, DAVID S. RATNER,
MARTHA M. MCBRAYER, ARLENE B. MORELLI,
and MORELLI ALTERS RATNER, LLP,
Plaintiffs,
-against-
BENJAMIN WEY, NYG CAPITAL LLC d/b/a NEW
YORK GLOBAL GROUP, and FNL MEDIA LLC,
Defendants.
x
Index No.
Date Purchased: July 15, 2015
SUMMONS WITH NOTICE
Plaintiffs designate New York
County as the place of trial.
Venue is proper pursuant to
C.P.L.R. § 503(a) and (c).
YOU ARE HEREBY SUMMONED to serve a notice of appearance or demand for the
complaint on plaintiffs' attorneys within 20 days after the service of this summons, exclusive of
the day of service (or within 30 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,
judgment will be taken against you by default for the relief demanded in the notice set forth
below.
Notice: The nature of this action is: 1) for damages for defamation, defamation per se,
and conspiracy to commit defamation in connection with defendants' malicious publication of
false and defamatory statements, images and information concerning plaintiffs in The Blot
Magazine and other public websites and forums; 2) for a permanent injunction barring
defendants from publishing such false and defamatory statements, images and information
concerning plaintiffs; and 3) for such other and further relief as the Court deems just and proper.
Upon your failure to appear, judgment will be taken against you by default for the relief
sought, including for compensatory damages of not less than $100 million, punitive damages of
EFTA01203561
not less than $200 million, and for injunctive, declaratory and equitable relief, together with
interest, attorneys' fees and costs, and such other relief as the Court may award.
Dated: New York, New York
July 15, 2015
KASOWITZ, BENSON, TORRES
& FRIEDMAN LLP
j:
By
Marc E. Kasowitz
David E. Ross
Kim Conroy
1633 Broadway
New York, New York 10019
(212) 506-1700
Attorneys for Plaintiffs
To:
Benjamin Wey
NYG Capital LLC
do Benjamin Wey
40 Wall Street, 38th Floor
New York, NY 10005, USA
FNL MEDIA LLC
do Benjamin Wey
40 Wall Street, 38th Floor
New York, NY 10005, USA
EFTA01203562
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