CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO.

INDEX NO. UNASSIGNED

NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/24/2024

SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK
_________________________________________

ENDY CHAVEZ, Index No.

Plaintiff,

-against- SUMMONS WITH NOTICE

MELVIN MORA,

Defendants.
_________________________________________

To the above-named Defendant:

PLEASE TAKE NOTICE THAT YOU ARE HEREBY SUMMONED to appear in this

action by serving a notice of appearance on the Plaintiff's attorney, at the address set forth below,

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).

YOU ARE HEREBY NOTIFIED THAT should you fail to answer to appear, a judgment

will be entered against you by default for the relief demanded below.

Dated: May 24, 2024

Rye Brook, NY LEVINE & BLIT, PLLC

/s/ Matthew J. Blit

Matthew J. Blit, Esq
Attorneys for Plaintiffs
800 Westchester Avenue, Suite S-322
Rye Brook, NY 10118
Tel. (212) 967-3000
MBlit@LevineBlit.com

1
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 1 of 2
CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/24/2024

To:

Defendant, Melvin Mora

Notice: The nature of this action is breach of contract, fraud, conversion, promissory

estoppel, and unjust enrichment.

Defendant caused plaintiff to provide significant monies to defendant under the promise

and fraudulent misrepresentation that defendant would repay plaintiff in installments a total of

approximately no less than $1.2 million beginning as of approximately 2019, with payments of the

balance of the promised funds continuing up to present. By providing said monies to defendant,

plaintiff detrimentally relied on defendant’s misrepresentations. Despite defendant’s promises and

fraudulent misrepresentations, defendant has failed and continues to fail to pay plaintiff and, at

present, has only paid plaintiff a small fraction of the promised $1.2 million payment. The relief

sought is monetary and compensatory damages; an award of punitive damages; pre-judgment and

post-judgment interest; and, an award of Plaintiff’s reasonable attorneys’ fees, costs and

disbursements.

Should Defendants fail to appear herein, judgment will be entered by default for the sum

of $5,000,000 with interest, and the fees and costs of this action.

Venue: Plaintiff designates New York County as the place of trial. The basis of this

designation is that defendant routinely conducts business in New York County.

2
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 2 of 2