Not Motion in Ooo Grazhdan Proyek Stroi v. Prometheus Capital Trust, S.A., Prometheus Capital Group, Prometheus Capital Bank, John Bloch a/k/a John T. Bloch a/k/a Dr. John Bloch, Robert Andreas, Robert L. Reese, William M. Pinzler Esq., Alberto Arce, Carl Brunner Esq| Trellis.Law

On June 07, 2019 a Notice of Appeal was filed involving a dispute between Ooo Grazhdan Proyek Stroi, and Alberto Arce, Carl Brunner Esq, John Bloch A K A John T. Bloch A K A Dr. John Bloch, Prometheus Capital Bank, Prometheus Capital Group, Prometheus Capital Trust, S.A., Robert Andreas, Robert L. Reese, William M. Pinzler Esq., for Commercial - Contract in the District Court of New York County.

Preview
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
-------------------------------------------------------------------x
OOO GRAZHDAN PROYEK STROI, a
Republic of Adygea limited liability company, Index No. 653363/2019

Plaintiff, NOTICE OF APPEAL

- against -

PROMETHEUS CAPITAL TRUST, S.A.,
PROMETHEUS CAPITAL GROUP,
PROMETHEUS CAPITAL BANK,
JOHN BLOCH a/k/a JOHN T. BLOCH
a/k/a DR. JOHN BLOCH, ROBERT ANDREAS,
ROBERT L. REESE, WILLIAM M. PINZLER, ESQ.,
ALBERTO ARCE and CARL BRUNNER, ESQ.,

Defendants.
-------------------------------------------------------------------x

PLEASE TAKE NOTICE that plaintiff OOO Grazhdan Proyek Stroi hereby appeals to

the Appellate Division of the Supreme Court of the State of New York, First Judicial Department

from a Decision and Order of the Supreme Court, New York County, by the Honorable Louis L.

Nock, J.S.C., dated March 5, 2024 and entered in the office of the New York County Clerk on

March 8, 2024.

Dated: New York, New York
April 5, 2024
FLEISCHMANN PLLC
Attorneys for Plaintiff
OOO Grazhdan Proyek Stroi

By: ______________________
Jeffrey Fleischmann, Esq.
150 Broadway, Suite 701
New York, New York 10038
Tel: (646) 657-9623
Fax: (646) 351-0694
jf@lawjf.com

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Informational Statement (Pursuant to 22 NYCRR 1250.3 [a]) - Civil

Case Title: Set forth the title of the case as it appears on the summons, notice of petition or order to For Court of Original Instance
show cause by which the matter was or is to be commenced, or as amended.

Date Notice of Appeal Filed
- against -

For Appellate Division

Case Type Filing Type

Civil Action CPLR article 78 Proceeding Appeal Transferred Proceeding
CPLR article 75 Arbitration Special Proceeding Other Original Proceedings CPLR Article 78
Action Commenced under CPLR 214-g CPLR Article 78 Executive Law § 298
Habeas Corpus Proceeding
Eminent Domain CPLR 5704 Review
Labor Law 220 or 220-b
Public Officers Law § 36
Real Property Tax Law § 1278

Nature of Suit: Check up to of the following categories which best reflect the nature of the case.

Administrative Review Business Relationships Commercial Contracts
Declaratory Judgment Domestic Relations Election Law Estate Matters
Family Court Mortgage Foreclosure Miscellaneous Prisoner Discipline & Parole
Real Property Statutory Taxation Torts
(other than foreclosure)

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Appeal
Paper Appealed From (Check one only): If an appeal has been taken from more than one order or
judgment by the filing of this notice of appeal, please
indicate the below information for each such order or
judgment appealed from on a separate sheet of paper.
Amended Decree Determination Order Resettled Order
Amended Judgement Finding Order & Judgment Ruling
Amended Order Interlocutory Decree Partial Decree Other (specify):
Decision Interlocutory Judgment Resettled Decree
Decree Judgment Resettled Judgment
Court: County:
Dated: Entered:
Judge (name in full): Index No.:
Stage: Interlocutory Final Post-Final Trial: Yes No If Yes: Jury Non-Jury
Prior Unperfected Appeal Information

Are any appeals arising in the same action or proceeding currently pending in the court? Yes No
If Yes, please set forth the Appellate Division Case Number assigned to each such appeal.

Where appropriate, indicate whether there is any related action or proceeding now in any court of this or any other
jurisdiction, and if so, the status of the case:

Original Proceeding

Commenced by: Order to Show Cause Notice of Petition Writ of Habeas Corpus Date Filed:
Statute authorizing commencement of proceeding in the Appellate Division:

Proceeding Transferred Pursuant to CPLR 7804(g)
Court: County:
Judge (name in full): Order of Transfer Date:
CPLR 5704 Review of Ex Parte Order:
Court: County:
Judge (name in full): Dated:
Description of Appeal, Proceeding or Application and Statement of Issues
Description: If an appeal, briefly describe the paper appealed from. If the appeal is from an order, specify the relief
requested and whether the motion was granted or denied. If an original proceeding commenced in this court or transferred
pursuant to CPLR 7804(g), briefly describe the object of proceeding. If an application under CPLR 5704, briefly describe the
nature of the ex parte order to be reviewed.

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Issues: Specify the issues proposed to be raised on the appeal, proceeding, or application for CPLR 5704 review

Party Information

Instructions: Fill in the name of each party to the action or proceeding, one name per line. If this form is to be filed for an
appeal, indicate the status of the party in the court of original instance and his, her, or its status in this court, if any. If this
form is to be filed for a proceeding commenced in this court, fill in only the party’s name and his, her, or its status in this
court.

No. Party Name Original Status Appellate Division Status
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
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18
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Attorney Information

Instructions: Fill in the names of the attorneys or firms for the respective parties. If this form is to be filed with the
notice of petition or order to show cause by which a special proceeding is to be commenced in the Appellate Division,
only the name of the attorney for the petitioner need be provided. In the event that a litigant represents herself or
himself, the box marked “Pro Se” must be checked and the appropriate information for that litigant must be supplied
in the spaces provided.

Attorney/Firm Name:
Address:
City: State: Zip: Telephone No:
E-mail Address:
Attorney Type: Retained Assigned Government Pro Se Pro Hac Vice
Party or Parties Represente (set forth party number(s) from table above :
Attorney/Firm Name:
Address:
City: State: Zip: Telephone No:
E-mail Address:
Attorney Type: Retained Assigned Government Pro Se Pro Hac Vice
Party or Parties Represented (set forth party number(s) from table above :
Attorney/Firm Name:
Address:
City: State: Zip: Telephone No:
E-mail Address:
Attorney Type: Retained Assigned Government Pro Se Pro Hac Vice
Party or Parties Represented (set forth party number(s) from table above :
Attorney/Firm Name:
Address:
City: State: Zip: Telephone No:
E-mail Address:
Attorney Type: Retained Assigned Government Pro Se Pro Hac Vice
Party or Parties Represented (set forth party number(s) from table above :
Attorney/Firm Name:
Address:
City: State: Zip: Telephone No:
E-mail Address:
Attorney Type: Retained Assigned Government Pro Se Pro Hac Vice
Party or Parties Represented (set forth party number(s) from table above :
Attorney/Firm Name:
Address:
City: State: Zip: Telephone No:
E-mail Address:
Attorney Type: Retained Assigned Government Pro Se Pro Hac Vice
Party or Parties Represented (set forth party number(s) from table above :

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
------------------------------------------------------------------X
OOO GRAZHDAN PROYEK STROI, a Index No. 653363/2019
Republic of Adygea limited liability company,
NOTICE OF ENTRY
Plaintiff,

- against -

PROMETHEUS CAPITAL TRUST, S.A.,
PROMETHEUS CAPITAL GROUP, PROMETHEUS
CAPITAL BANK, JOHN BLOCH a/k/a JOHN T.
BLOCH a/k/a DR. JOHN BLOCH, ROBERT
ANDREAS, ROBERT L. REESE, WILLIAM M.
PINZLER, ESQ., ALBERTO ARCE and CARL
BRUNNER, ESQ.,
Defendants.
------------------------------------------------------------------X

PLEASE TAKE NOTICE that the annexed is a true copy of the Decision and Order,

dated March 5, 2024, and entered in the Clerk’s Office of the Supreme Court of the State of New

York, County of New York, on March 8, 2024, in the above-captioned action,

Date: New York, New York
March 8, 2024
ABRAMS GARFINKEL
MARGOLIS BERGSON, LLP

By:___________________
Andrew W. Gefell
1430 Broadway, 8th Floor
New York, New York 10018
(212) 201-1170
Attorneys for Defendant
William M. Pinzler, Esq.

TO: All counsel of record, by NYSCEF

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SUPREME COURT OF THE STATE OF NEW YORK
NEW YORK COUNTY
PRESENT: HON. LOUIS L. NOCK PART 38M
Justice
---------------------------------------------------------------------------------X INDEX NO. 653363/2019
OOO GRAZHDAN PROYEK STROI,
MOTION DATE 02/08/2023
Plaintiff,
MOTION SEQ. NO. 003
-v-
PROMETHEUS CAPITAL TRUST, S.A., PROMETHEUS
CAPITAL GROUP, PROMETHEUS CAPITAL BANK, JOHN
BLOCH, ROBERT ANDREAS, ROBERT L. REESE, DECISION + ORDER ON
WILLIAM M. PINZLER, ALBERTO ARCE, and CARL MOTION
BRUNNER,

Defendants.
---------------------------------------------------------------------------------X

The following e-filed documents, listed by NYSCEF document numbers (Motion 003) 30, 31, 32, 33, 51,
71, 73, 74, 75, 76, 77, 78, 79, 80, 81, 82, 83, 84, 85, 86, 87, 88, 89, 91, 92, 93, 94, 95, 96, and 97
were read on this motion to DISMISS .

LOUIS L. NOCK, J.S.C.

Upon the foregoing documents, the motion by defendant William M. Pinzler to dismiss

the complaint pursuant to CPLR 3211(a)(7) and (a)(10) for failure to state a cause of action and

failure to join a necessary party is granted, and the cross-motion by plaintiff for an extension of

time to serve and to amend the complaint pursuant to CPLR 306-b and 3025 is denied, for the

reasons set forth in the as set forth in the following memorandum.

Background

As alleged in the complaint, this action arises out of agreements between plaintiff and

defendants Prometheus Capital Trust, S.A., Prometheus Capital Group, and Prometheus Capital

Bank (collectively, “Prometheus”), pursuant to which plaintiff “was to be assigned by lease a

portfolio of securities for use by plaintiff as collateral for a bank loan to be arranged by

Prometheus” (complaint, NYSCEF Doc. No. 1, ¶ 1). Defendant Pinzler functioned as

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Prometheus’ outside counsel, and is the only defendant to have been served. The remaining

defendants are alleged to be officers and representatives of Prometheus (id., ¶¶ 13-15, 17).

Plaintiff alleges that it forwarded “hundreds of thousands of dollars” to Prometheus to

cover a contract deposit and insurance premiums, but Prometheus never assigned the portfolio of

securities to plaintiff and failed to procure the bank loan for Prometheus (id., ¶ 2). None of the

funds sent to Prometheus, which plaintiff asserts were sent through defendant Pinzler, were ever

returned, totaling not less than $1,000,000 (id., ¶¶ 3-4). Plaintiff asserts that the entire

transaction was fraudulent, including, that the individual defendants may have used “aliases and

false identities to perpetrate their fraud” (id., ¶ 6).

Plaintiff commenced this action on June 7, 2019. Pinzler filed an answer to the

complaint on September 27, 2019. Since that time, no other defendant has been served, nor has

plaintiff sought an extension of time to do so until the present motion practice. Plaintiff asserts

that it has attempted, through discovery and through private investigators, to locate the

defendants for service (Chigintsev aff., NYSCEF Doc. No. 77, ¶¶ 51-56), but has not provided

any proof of the details of those searches, whether by documentary evidence or affidavits of the

investigators.

Standard of Review

“On a motion to dismiss pursuant to CPLR 3211, the pleading is to be afforded a liberal

construction” (Leon v Martinez, 84 NY2d 83, 87 [1994]). “[The court] accept[s] the facts as

alleged in the [pleading] as true, accord[ing the nonmovant] the benefit of every possible

favorable inference, and determin[ing] only whether the facts as alleged fit within any cognizable

legal theory” (id. at 87-88). Ambiguous allegations must be resolved in the nonmovant’s favor

(JF Capital Advisors, LLC v Lightstone Group, LLC, 25 NY3d 759, 764 [2015]). “The motion

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must be denied if from the pleadings' four corners factual allegations are discerned which taken

together manifest any cause of action cognizable at law” (511 West 232nd Owners Corp. v

Jennifer Realty Co., 98 NY2d 144, 152 [2002] [internal citations omitted]). “[W]here . . . the

allegations consist of bare legal conclusions, as well as factual claims either inherently incredible

or flatly contradicted by documentary evidence, they are not entitled to such consideration”

(Ullmann v Norma Kamali, Inc., 207 AD2d 691, 692 [1st Dept 1994]).

Discussion

Failure to Join a Necessary Party (CPLR 3211[a][10])

Pinzler first moves to dismiss the complaint because plaintiff has failed to serve the

Prometheus entities, who are the only parties to the contract with plaintiff. A party may move to

dismiss a complaint on the ground that “the court should not proceed in the absence of a person

who should be a party” (CPLR 3211[a][10]). “Persons who ought to be parties if complete relief

is to be accorded between the persons who are parties to the action or who might be inequitably

affected by a judgment in the action shall be made plaintiffs or defendants” (CPLR 1001[a]).

“By nature and definition, the issue arises under CPLR 3211(a)(10) only where a potentially

affected party is not named in the caption of the action” (Hon. Mark C. Dillon, Practice

Commentaries, McKinney’s Cons Laws of NY, CPLR C3211:32 [2020]). Here, the Prometheus

entities have been joined as parties and named in the action, and, therefore, this branch of

Pinzler’s motion must be denied.

Pinzler’s cited cases1 are not to the contrary (Germain v Town of Chester Planning Bd.,

178 AD3d 926, 927 [2d Dept 2019] [“We agree with the Supreme Court's determination to grant

dismissal of the petition for failure to timely join the landowner, Chill Factor”]; Cabrera v City

1
Pinzler Mem. (NYSCEF Doc. No. 33) at 6, 7, 17.
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of N.Y. Civ. Serv. Comm'n, 2019 WL 112721 at * 2 [Sup Ct, NY County, 2019] [“Having failed

to timely join the DOC and New York City as necessary parties, the court is compelled to

dismiss the petition”], affd 181 AD3d 540 [1st Dept 2020]; Taurus Petroleum Ltd. v Global

Emerging Markets North America, Inc., 2018 NY Slip Op 31264[U] at *21 [Sup Ct, NY County,

2018] [dismissing complaint for failure to name borrower and entity that received money from

borrower, who were not named]).2

Failure to State a Cause of Action (CPLR 3211[a][7])

Plaintiff alleges three causes of action directly against Pinzler: fraud, unjust enrichment,

and conversion. “Generally, in a claim for fraudulent misrepresentation, a plaintiff must allege a

misrepresentation or a material omission of fact which was false and known to be false by

defendant, made for the purpose of inducing the other party to rely upon it, justifiable reliance of

the other party on the misrepresentation or material omission, and injury” (Mandarin Trading

Ltd. v Wildenstein, 16 NY3d 173, 178 [2011]). Allegations of fraud must include who spoke,

what they said, and the date on which they said it (E1 Entertainment U.S. LP v Real Talk

Entertainment, Inc., 85 AD3d 561, 562 [1st Dept 2011]). Here, plaintiff fails to plead fraud with

requisite particularity (CPLR 3016[b]). First, plaintiff engages in impermissible group pleading

(Principia Partners LLC v Swap Fin. Group, LLC, 194 AD3d 584, 584 [1st Dept 2021] [“The

complaint failed to distinguish between the entities and was an improper group pleading”]).

2
The court takes note of Pinzler’s citation to one decision rendered by a court of concurrent jurisdiction herewith –
Rocket Shippers, LLC v SB Glob. Ventures PTE Ltd. (2022 NY Slip Op 33721[U] at *3 [Sup Ct, NY County, 2022]
[Saunders, J.]) – granting dismissal on grounds of a plaintiff’s failure to serve a named defendant; however, the
undersigned elects, instead, to follow the plain dictate of CPLR 3211(a)(10) and the official Practice Commentary
thereon (see, Hon. Mark C. Dillon, Practice Commentaries, McKinney’s Cons Laws of NY, CPLR C3211:32 [2020]
[“By nature and definition, the issue arises under CPLR 3211(a)(10) only where a potentially affected party is not
named in the caption of the action”] [emphasis added]).

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Second, the complaint fails to allege what misrepresentations Pinzler allegedly made, who he

made them to, or when he made them (E1 Entertainment U.S. LP, supra).

Moreover, where a fraud claim arises out of the same facts and seeks the same damages

as a claim for breach of contract, it must be dismissed as duplicative (see Fairway Prime Estate

Mgt., LLC v First American Intl. Bank, 99 AD3d 554, 557 [1st Dept 2012] [“if the promise

concerned the performance of the contract itself, the fraud claim is subject to dismissal as

duplicative of the claim for breach of contract”]; HSH Nordbank AG v UBS AG, 95 AD3d 185,

206 [1st Dept 2012] [dismissing fraud claim based in part on alleged insincere promise regarding

the manner of performance]). While pled against separate defendants, the breach of contract and

fraud claims arise out of the same facts, namely, Prometheus’ failure to perform under the

agreement with plaintiff.

Turning to the unjust enrichment and conversion causes of action, they, too, arise out of

the same facts as the breach of contract claim and must be dismissed as duplicative Clark-

Fitzpatrick, Inc. v Long Island R.R. Co., 70 NY2d 382, 388 [1987] [unjust enrichment]; Richbell

Information Services, Inc. v Jupiter Partners, LP, 309 AD2d 288, 306 [1st Dept 2003]

[conversion]). Plaintiff does not, in actuality, allege a duty collateral to the contract that could

give rise to tort liability (Brown v Brown, 12 AD3d 176 [1st Dept 2004]).

Finally, plaintiff alleges claims against Pinzler for “concerted action liability” and “aiding

and abetting liability” (complaint, NYSCEF Doc. No. 1, ¶¶ 79-87). To the extent that plaintiff

alleges civil conspiracy, such a separate tort does not exist under New York law (Mamoon v Dot

Net Inc., 135 AD3d 656, 658 [1st Dept 2016]). Moreover, as set forth above, the tort claims

underlying such claims are all insufficiently pled. In order to allege aiding and abetting liability,

it is necessary to plead the underlying tort sufficiently, and plaintiff has not done so (Oster v

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Kirschner, 77 AD3d 51, 55 [1st Dept 2010] [“A plaintiff alleging an aiding-and-abetting fraud

claim must allege the existence of the underlying fraud”]).

Accordingly, so much of Pinzler’s motion to dismiss the complaint for failure to state a

cause of action is granted.

Cross-Motion for Leave to Amend the Complaint (CPLR 3025)

Leave to amend a pleading should be freely given, but a court must first examine the

merits of the proposed amendment (Pier 59 Studios, L.P. v Chelsea Piers, L.P., 40 AD3d 363,

365-66 [1st Dept 2007]). An amendment to a complaint may not “be based on facts that would

contradict the original theory” (Brunetti v Musallam, 59 AD3d 220, 223 [1st Dept 2009] [internal

quotation marks and citations omitted]). Here, plaintiff originally alleged that Prometheus

breached the agreement with plaintiff with the aid of its counsel, Pinzler, and other officers and

agents of Prometheus. While plaintiff alleged that some of the individual defendants were

operating under aliases or false identities, plaintiff did not claim that any defendant was a

fictitious person or entity. In the amended complaint, plaintiff now alleges a wholly different

factual underpinning for its claims. Specifically, plaintiff now attempts to pin the entire scheme

on Pinzler, alleging that the other entities named in the complaint are entirely fictitious creations

of Pinzler in furtherance of his alleged scheme to defraud plaintiff. This is markedly different

from the allegations originally made against Pinzler as one among several individual defendants.

It does not go unnoticed that Pinzler is thus far the only defendant who has been served.

Moreover, as set forth by Pinzler, Prometheus Capital Trust, S.A., appears to be an operating

entity domiciled in Costa Rica (Prometheus corporate filings, NYSCEF Doc. No. 95). As

plaintiff’s two theories of liability are factually inconsistent, the cross-motion for leave to amend

is denied.

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Cross-Motion for an Extension of Time to Serve (CPLR 306-b)

Pursuant to CPLR 306-b, service of the summons and complaint shall be made within

120 days after the commencement of the action. Upon motion, a court may, within its discretion,

grant an extension of time within which to effect service for good cause shown or in the interest

of justice (Leader v Maroney, Ponzini & Spencer, 97 NY2d 95, 101 [2001]). While the “good

cause” standard requires a showing of reasonable diligence; under the broader “interest of

justice” standard, “the court may consider diligence, or lack thereof, along with any other

relevant factor in making its determination, including expiration of the Statute of Limitations, the

meritorious nature of the cause of action, the length of delay in service, the promptness of a

plaintiff’s request for the extension of time, and prejudice to defendant” (id. at 105).

Here, the court notes both the age of the case, and the length of time that plaintiff waited

until making this request. The court is also cognizant that plaintiff has been attempting through

discovery, subpoena practice (decision and order, NYSCEF Doc. No. 98), and otherwise to

determine the locations of the other defendants, though the affidavit of its principal is scant in

this regard (Chigintsev aff., NYSCEF Doc. No. 77, ¶¶ 51-56). Given the age of the case and the

timing of the allegations of the original complaint, it is likely that, in the absence of an extension,

at least some of plaintiff’s claims may be time-barred, due in no small part to the difficulty in

locating defendants, as well as the myriad delays and impediments imposed by the COVID-19

pandemic from 2020 onward. In addition, the complaint adequately alleges, at minimum, a

cause of action for breach of contract against Prometheus. The court, therefore, grants the

motion in the interests of justice, and extends plaintiff’s time to serve the remaining defendants

with the summons and complaint (NYSCEF Doc. No. 1) for sixty days following the filing by

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the court of this decision and order. Given the information provided by Pinzler in opposition to

the cross-motion, that should be sufficient time to, at least, serve Prometheus.

Accordingly, it is hereby

ORDERED that the motion to dismiss the complaint as to defendant William M. Pinzler

for failure to state a cause of action is granted; and it is further

ORDERED that the Clerk of the Court is directed to enter judgment in favor of defendant

William M. Pinzler and against plaintiff dismissing the complaint against Pinzler, with costs and

disbursements as taxed by the Clerk upon submission of an appropriate bill of costs; and it is

further

ORDERED that the action is severed and continued as against the remaining defendants;

and it is further

ORDERED that so much of the cross-motion for leave to serve an amended complaint is

denied; and it is further

ORDERED that so much of the cross-motion for an extension of time to serve the

original complaint (NYSCEF Doc. No. 1) is granted to the extent that plaintiff’s time to serve the

remaining defendants with said original complaint is extended to sixty days following the date of

the filing by this court of this decision and order; and it is further

ORDERED that this order is in no way determinative of the tolling of the statute of

limitations or other issues of repose, should such issues arise.

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101 RECEIVED NYSCEF: 04/05/2024
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This constitutes the decision and order of the court.

ENTER:

3/5/2024 $SIG$
DATE LOUIS L. NOCK, J.S.C.
CHECK ONE: CASE DISPOSED X NON-FINAL DISPOSITION

X GRANTED DENIED GRANTED IN PART OTHER

APPLICATION: SETTLE ORDER SUBMIT ORDER

CHECK IF APPROPRIATE: INCLUDES TRANSFER/REASSIGN FIDUCIARY APPOINTMENT REFERENCE

653363/2019 OOO GRAZHDAN PROYEK STROI vs. PROMETHEUS CAPITAL TRUST, S.A. ET Page 9 of 9
AL
Motion No. 003

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FILED: NEW YORK COUNTY CLERK 04/05/2024 02:23 PM INDEX NO. 653363/2019
NYSCEF DOC. NO. 102 RECEIVED NYSCEF: 04/05/2024

-against-

Defendants.
-------------------------------------------------------------------x

AFFIRMATION OF SERVICE

JEFFREY FLEISCHMANN, an attorney duly admitted to practice before the Courts of

the State of New York, affirms under the penalty of perjury as follows: I am counsel for OOO

Grazhdan Proyek Stroi. On April 5, 2024, I caused to be served a copy of the within Notice of

Appeal and all the accompanying documents upon all parties via NYSCEF electronic filing as

follows:

Andrew W. Gefell
Abrams Garfinkel Margolis Bergson, LLP
1430 Broadway, 8th Floor
New York, New York 10018
Attorneys for Defendant William M. Pinzler, Esq.

[SIGNATURE ON FOLLOWING PAGE]

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FILED: NEW YORK COUNTY CLERK 04/05/2024 02:23 PM INDEX NO. 653363/2019
NYSCEF DOC. NO. 102 RECEIVED NYSCEF: 04/05/2024

Dated: New York, New York
April 5, 2024
FLEISCHMANN PLLC
Attorneys for Plaintiff OOO Grazhdan Proyek Stroi

By: ______________________
Jeffrey Fleischmann, Esq.
150 Broadway, Suite 701
New York, New York 10038
Tel: (646) 657-9623
Fax: (646) 351-0694
jf@lawjf.com

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Case Info

Judge

Louis L. Nock Track Judge’s New Case

Case No.

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Document Filed Date

April 05, 2024

Case Filing Date

June 07, 2019

County

Parties

Alberto Arce Defendant
BERGSON, ROBERT JOSEPH Attorney for the Defendant
Carl Brunner ESQ Defendant
FLEISCHMANN, JEFFREY Attorney for the Plaintiff
GEFELL, ANDREW W. Attorney for the Defendant
HAUPTMAN, JONATHAN DAVID Attorney for the Defendants
HELLER, GARY M Attorney for the Plaintiff
John Bloch a/k/a John T. Bloch a/k/a Dr. John Bloch Defendant
OOO Grazhdan Proyek Stroi Plaintiff
Prometheus Capital Bank Defendant
Prometheus Capital Group Defendant
Prometheus Capital Trust, S.A. Defendant
Robert Andreas Defendant
Robert L. Reese Defendant
William M. Pinzler ESQ. Defendant
JOHN BOSCO Attorney
LESLIE REESE Attorney
KOSTAS GOLFINOPOULOS Attorney
William Mulderig Attorneys for Plaintiffs
JOHN BOOTH Attorney
WILLIAM PIER Attorney
William Shapiro Attorney
JEFFREY FLEISCHMAN Attorneys for Plaintiffs

For full print and download access, please subscribe at https://www.trellis.law/.

Notice of Appeal: Ooo Grazhdan Proyek Stroi v. Prometheus Capital Trust, S.A., Prometheus Capital Group, Prometheus Capital Bank, John Bloch a/k/a John T. Bloch a/k/a Dr. John Bloch, Robert Andreas, Robert L. Reese, William M. Pinzler Esq., Alberto Arce, Carl Brunner Esq

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Case Info

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