AS.CHI.23 21:07 9 oi si ls a SUPREME COURT OF THE STATE OF NEW YORE COUNTY OF NEW YORE ee YERKEL WEINSTOCK ond JB TRADING INTERNATIONAL, LTD.» Plaintiffs, Verifie: ‘EMMERICH: HANDLER, RITA HANDLER, MARK LICHTSCREIN and GLENWOOD ESTATES ASSOCIATES, res Defendants. eT NNT AMT Plaintiffs, by their attorneys Israel complaining of the defendante, atiess 09 follovst ' AS AND FOR A FIRST CAUSE OF ACTION Weinstock vas, end still is, an attorney duly New York, New Yorks business at 350 Broadvay, New Yorks New Tork. 3. That, pon information ead verted. | hereinafter mentioned, Emmerich and Rite Handler. were residents of the State of Nev Tork. db. That, upon information and belief wagainst— Index No. 1. That, at all times hereinafter mentioned, Terael | prectice of lav in the courte of. the State of New York, | meintaining sa office for the practice of law at 350 Broadyayy 2, That, at all times hereinsfter mentioned, JB Trading International, Ltd.,("JB") ves © corporation duly incorporated under the lava of the State of Nev York as a nominee of Israel), Weinstock, meinteining an office for the transaction of such 4 Complaint Weinstock, Eeq, admitted to the at ell times at all tiresident of the hereinafter mentioned, Mark Lichtecheio State of New Tork. S$. That, upon information and belief, at sil tines hereinafter mentioned, Glenwood Estates Associates was © Limited pertoership duly formed under the lave of the State of Rew York. 6.°. That,: on or about February 15th, 1985, Jeck and Anite Walker, general and limited partners respectively in Clenvood Hotates Associates, assigned, iater alia, all their right, eitie and interest da Glenvood Eatates Associates to Weinstock and mB | for good and valuable consideration. 7. That Jack Walker's general partnership vas 5% of Glenvood Estates Associates and that Anite Walker's limited i partnership was 60% of Clenvood Retates Associates. 8. That the assignment made by the Walkere to Weinstock end JB dneluded ali of the Walkers’ rights under a conditions? aesignment and = $40,000 prosissory note from “gumerich Randler™ | (Rite Handler), and Lichtschein as purchasers of the Walkers’ | dnterest dn an entity kaown sa Glenwood Gardens Associates. 9. That, upen information and belief, Rite Hendler and Lichtachein were to pay, in consideration of the conditions assignment from the Walkers of their interest $2 Glenvood Gardens Associates, $40,000 upon sigaing the agreenent to sssign and further sums upon the fulfilment of certain condition 10, Thet, upon information and belief, Rite Handler and Lichtschein gave the Walkers a promissory note upon the signing of the agreement to assign and single partie] peyment on the note sometime afterward. sazthe conditional in Glenvood Gardens Associates by making no farther payments thereon before February-15th, 1985, the date upon which Weinstock gave the Walkers good and valuable consideration 4n full for all octates their right, title and interest in Glenvood Eetates Ai and in the conditional assignment regerdt) Glenwood Gardens Associa’ ia. That-the conditional assignment by the Walkers to Rite Handler and Lichtschein is void as 6 satter of lev for lack of considerations 13. That plaiatifte are the legal and equitable owner © all of the Walkers’ right, title and interest tn Glenwood Estates! Associates and of all the Walkers’ rights ‘ander the promissory! a) Lichtschein. | ‘ ignment to Rite Hendler note and the conditional 14, ‘That plaintiffs, as such legal and equitable ovners of Glenvood Estates Associates, ere entitled to ao accounting. from’ all defendants regarding Clenvood Eatates Associates and have received no auch accounting. AS AND FOR A SECOND CAUSE OF ACTION : 15. Plaintiffs vepeat aad reallege cach and every| allegation contained in paragraphs "1" through "13", inclusive, as if fully set forth herein. 16, Thar, upon Amformation and belief, Rita Hendler a cI Liehtechein have held themselves out as part-owners of Glenvood) TNT aTTTuaMNniniill