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M&T Bank v. Prestige Realty Group Inc., National Billing And Funding Llc, Consumer Protection Restoration Llc, Wetzer Jeannot

A Commercial - Contract case was filed by (Subcribe to view) represented by (Subcribe to view) against (Subscribe to view) in the jurisdiction of Rockland County.

Case Details

Case Number

(Subscribe to View)   

Filing Date

March 13, 2024

Last Refreshed

March 16, 2024

Filing Location

Rockland County, NY

Category

Commercial - Contract

Practice Area

Commercial

Matter Type

Breach of Contract

Status

Active

Overview

Plaintiff repeats and realleges the allegations contained in Paragraphs “1” through

“6” of this Complaint with the same force and effect as if set forth fully at length herein.

On or about January 9, 2020, M&T Bank and Borrowers entered into a Loan

Agreement (the “Loan Agreement”), whereby M&T Bank agreed, from time to time, in its sole

discretion, to make one or more loans to or for the account of Borrowers upon any Borrower’s

request. A true and correct copy of the Loan Agreement is attached hereto as Exhibit A.

4247903 -2-

Causes of Action

FACTS COMMON TO ALL CAUSES OF ACTION

1. Breach of Contract (Borrowers)

2. Breach of Contract (Prestige Realty Group Inc.)

3. Breach of Guaranty (Wetzer Jeannot)

4. Replevin (Borrowers)

5. Permanent Injunction (Borrowers)

Case Complaint Summary

This legal document filed by M&T Bank involves a complaint against Prestige Realty Group Inc., National Billing and Funding LLC, Consumer Protection Restoration LLC, and Wetzer Jeannot for breach of contract and failure to pay obligations under L…...

Parties

Plaintiffs

M&T Bank

Attorneys for Plaintiffs

Bieber, Bruce Wayne

Defendants

Consumer Protection Restoration Llc
National Billing And Funding Llc
Prestige Realty Group Inc.
Wetzer Jeannot

Case Documents

EXHIBIT(S) - B

Date: Mar 15, 2024

EXHIBIT(S) - A

Date: Mar 15, 2024

AFFIRMATION

Date: Mar 15, 2024

EXHIBIT(S) - N

Date: Mar 15, 2024

EXHIBIT(S) - M

Date: Mar 15, 2024

EXHIBIT(S) - L

Date: Mar 15, 2024

EXHIBIT(S) - K

Date: Mar 15, 2024

EXHIBIT(S) - I

Date: Mar 15, 2024

EXHIBIT(S) - J

Date: Mar 15, 2024

EXHIBIT(S) - H

Date: Mar 15, 2024

EXHIBIT(S) - F

Date: Mar 15, 2024

EXHIBIT(S) - E

Date: Mar 15, 2024

EXHIBIT(S) - C

Date: Mar 15, 2024

EXHIBIT(S) - D

Date: Mar 15, 2024

EXHIBIT(S) - B

Date: Mar 15, 2024

EXHIBIT(S) - A

Date: Mar 15, 2024

EXHIBIT(S) - P

Date: Mar 13, 2024

EXHIBIT(S) - K

Date: Mar 13, 2024

EXHIBIT(S) - O

Date: Mar 13, 2024

EXHIBIT(S) - L

Date: Mar 13, 2024

EXHIBIT(S) - N

Date: Mar 13, 2024

EXHIBIT(S) - B

Date: Mar 13, 2024

EXHIBIT(S) - M

Date: Mar 13, 2024

EXHIBIT(S) - J

Date: Mar 13, 2024

EXHIBIT(S) - D

Date: Mar 13, 2024

EXHIBIT(S) - I

Date: Mar 13, 2024

EXHIBIT(S) - H

Date: Mar 13, 2024

EXHIBIT(S) - F

Date: Mar 13, 2024

EXHIBIT(S) - A

Date: Mar 13, 2024

EXHIBIT(S) - C

Date: Mar 13, 2024

EXHIBIT(S) - E

Date: Mar 13, 2024

COMPLAINT

Date: Mar 13, 2024

SUMMONS

Date: Mar 13, 2024

Case Events

Type Description
RJI -RE: ORDER TO SHOW CAUSE
MEMORANDUM OF LAW IN SUPPORT Memorandum of Law in Support of Plaintiff's Order to Show Cause for Preliminary Injunction and Tempo
Memorandum of Law in Support of Plaintiff's Order to Show Cause for Preliminary Injunction and Tempo ... show more
EXHIBIT(S) - B
Ex. B to Bieber Aff. - Complaint
EXHIBIT(S) - A
Ex. A to Bieber Aff. - Zodda Letter
AFFIRMATION
Bieber Affirmation for Emergency Relief
EXHIBIT(S) - N
Ex. N to Pugh Aff. - Notice of Default, Acceleration, and Demand for Payment
EXHIBIT(S) - M
Ex. M to Pugh Aff. - Notice of Default and Reservation of Rights
EXHIBIT(S) - L
Ex. L to Pugh Aff. - UCC Financing Statements
EXHIBIT(S) - K
Ex. K to Pugh Aff. - Second CPR Security Agreement
EXHIBIT(S) - I
Ex. I to Pugh Aff. - Second Prestige Security Agreement
EXHIBIT(S) - J
Ex. J to Pugh Aff. - Second National Billing Security Agreement
EXHIBIT(S) - H
Ex. H to Pugh Aff. - Jeannot Unlimited Guaranty
EXHIBIT(S) - F
Ex. F to Pugh Aff. - Jeannot Unlimited Guaranty
EXHIBIT(S) - G Ex. G to Pugh Aff. - Credit Card Agreement Redacted per 22 NYCRR
Ex. G to Pugh Aff. - Credit Card Agreement Redacted
EXHIBIT(S) - E
Ex. E to Pugh Aff. - First CPR Security Agreement
EXHIBIT(S) - C
Ex. C to Pugh Aff. - First Prestige Security Agreement
EXHIBIT(S) - D
Ex. D to Pugh Aff. - First National Billing Security Agreement
EXHIBIT(S) - B
Ex. B to Pugh Aff. - Revolving Demand Note
EXHIBIT(S) - A
Ex. A to Pugh Aff. - Loan Agreement
AFFIDAVIT OR AFFIRMATION IN SUPPORT OF PROPOSED OSC/EXPARTE APP
Pugh Affirmation in Support of Order to Show Cause
ORDER TO SHOW CAUSE ( PROPOSED )
EXHIBIT(S) - P
Ex. P - Credit Card Statement
EXHIBIT(S) - K
Ex. K - Second CPR Security Agreement
EXHIBIT(S) - O
Ex. O - Prestige Line of Credit Statement
EXHIBIT(S) - L
Ex. L - Financing Statements
EXHIBIT(S) - N
Ex. N - Notice of Default, Acceleration, and Demand for Payment
EXHIBIT(S) - B
Ex. B - Revolving Demand Note
EXHIBIT(S) - M
Ex. M - Notice of Default and Reservation of Rights
EXHIBIT(S) - J
Ex. J - Second National Billing Security Agreement
EXHIBIT(S) - D
Ex. D - First National Billing Security Agreement
EXHIBIT(S) - I
Ex. I - Second Prestige Security Agreement
EXHIBIT(S) - H
Ex. H - Jeannot Continuing Guaranty
EXHIBIT(S) - G Ex. G - Credit Card Agreement Redacted per 22 NYCRR
Ex. G - Credit Card Agreement Redacted
EXHIBIT(S) - F
Ex. F - Jeannot Unlimited Guaranty
EXHIBIT(S) - A
Ex. A - Loan Agreement
EXHIBIT(S) - C
Ex. C - Prestige Security Agreement
EXHIBIT(S) - E
Ex. E - First CPR Security Agreement
COMPLAINT
Verified Complaint
SUMMONS

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