`
`IN THE SUPREME COURT OF
`THE STATE OF NEW YORK,
`COUNTY OF NASSAU, AT AN
`IAS PART _______, AT THE
`COURTHOUSE LOCATED AT
`100 SUPREME COURT DRIVE,
`MINEOLA, NY
`11501 ON
`____________, 2020.
`
`HON. ___________________
`
`
`J.S.C.
`
`
`PRESENT:
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`
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NASSAU
`-----------------------------------------------------------------------X
`QUEEN FUNDING, LLC,
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`
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`Plaintiff,
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`Index No. 611523/2020
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`ORDER TO SHOW CAUSE
`FOR A PRELIMINARY
`INJUNCTION WITH
`TEMPORARY RESTRAINING
`ORDER
`
`
`
`
`
`-against-
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`HK CONTRACTORS LLC and
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`EMIL LAHAZIEL,
`
`
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`Defendants.
`
`-----------------------------------------------------------------------X
`UPON THE READING AND FILING of the annexed verified complaint, dated
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`October ____, 2020, the annexed affidavit or ______________, dated October ___ 2020, the
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`annexed affirmation of Israel D. Weinstein, Esq., dated October _____, 2020, and the
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`accompanying exhibits and memorandum of law, dated October ____, 2020,
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`LET DEFENDANTS, HK CONTRACTORS LLC and EMIL LAHAZIEL or
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`counsel appear before this Court on __________________, 2020, at an IAS Part _______, at the
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`Courthouse located at 100 Supreme Court Drive, Mineola, NY 11501, at __________a.m./p.m.,
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`1
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`and show cause why an Order should not issue Pursuant to CPLR 6301, granting a preliminary
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`injunction, pending the resolution of this action, restraining all funds held in the Defendants
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`accounts held at Bank of America, N.A. up until the amount sought in the verified complaint of
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`$652,500.
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`SUFFICIENT CAUSE HAVING BEEN ALLEGED, it is:
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`ORDERED, that pending the hearing of this application, Bank of America, N.A
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`and all persons acting on its behalf are hereby restrained and enjoined from releasing any funds up
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`until the amount of $652,500 in the account for Defendants HK CONTRACTORS LLC and EMIL
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`LAHAZIEL; and it is further
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`ORDERED, that Defendants shall serve any answering or responding papers upon
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`Weinstein & Weinstein, LLP, 68-15 Main Street, 2nd Floor, Flushing, NY 11367, as counsel for
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`Plaintiff, via New York State Court Electronic Filing (NYSCEF) so that said papers are received
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`by Plaintiff’s counsel at least ______ days before the return date hereof; and it is further
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`ORDERED, that Plaintiff shall submit any reply to the above responding papers
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`by at least _______ days before the above-mentioned return date; and it is further
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`ORDERED that service of a copy of this Order to Show Cause and supporting
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`documentation thereto, shall be deemed good and proper if served upon Bank of America, N.A.
`
`via fax at 1-617-310-2751 and via USPS Priority Mail to Bank of America, N.A., Legal Order
`
`Processing, P.O. Box 15047, Wilmington, DE 19850-5047 on or before ___________ day of
`
`_________________, 2020.
`
`IT IS FURTHER ORDERED that service of a copy of this Order to Show Cause
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`and its supporting papers, the summons and verified complaint with notice of electronic filing with
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`index number and filing date endorsed thereon, and the request for judicial intervention be made
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`
`
`2
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`
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`upon Defendants HK CONTRACTORS LLC and EMIL LAHAZIEL, in accordance with the
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`terms of the parties’ agreement, by USPS Priority Mail, addressed to 1911 NE 206TH TER
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`MIAMI, FL 33179 and 419 TAMARIND DR HALLANDALE BEACH, FL 33009 and 101
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`NORTH FEDERAL HWY HALLANDALE, FL 33009, on or before the ______ day of
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`__________________, 2020.
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`ENTER:
`
`_______________________
`
`Hon. _______________________, J.S.C.
`
`3
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