EFTA01203561.pdf

WILED: NEW YORK COUNTY CLERK 07/15/2015 12:41 Pl4 INDEX NO. 652489/2015 NYSCEF DOC. NC. RECEIVED NYSCEF: 07/15/2015 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK BENEDICT P. MORELLI, DAVID S. RATNER, Index No. MARTHA M. MCBRAYER, ARLENE B. MORELLI, and MORELLI ALTERS RATNER, LLP, Date Purchased: July 15, 2015 Plaintiffs, SUMMONS WITH NOTICE -against- Plaintiffs designate New York County as the place of trial. BENJAMIN WEY, NYG CAPITAL LLC d/b/a NEW YORK GLOBAL GROUP, and FNL MEDIA LLC, Venue is proper pursuant to C.P.L.R. § 503(a) and (c). Defendants. x YOU ARE HEREBY SUMMONED to serve a notice of appearance or demand for the complaint on plaintiffs' attorneys 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); and in case of your failure to appear, judgment will be taken against you by default for the relief demanded in the notice set forth below. Notice: The nature of this action is: 1) for damages for defamation, defamation per se, and conspiracy to commit defamation in connection with defendants' malicious publication of false and defamatory statements, images and information concerning plaintiffs in The Blot Magazine and other public websites and forums; 2) for a permanent injunction barring defendants from publishing such false and defamatory statements, images and information concerning plaintiffs; and 3) for such other and further relief as the Court deems just and proper. Upon your failure to appear, judgment will be taken against you by default for the relief sought, including for compensatory damages of not less than $100 million, punitive damages of EFTA01203561 not less than $200 million, and for injunctive, declaratory and equitable relief, together with interest, attorneys' fees and costs, and such other relief as the Court may award. Dated: New York, New York July 15, 2015 KASOWITZ, BENSON, TORRES & FRIEDMAN LLP j: By Marc E. Kasowitz David E. Ross Kim Conroy 1633 Broadway New York, New York 10019 (212) 506-1700 Attorneysfor Plaintiffs To: Benjamin Wey NYG Capital LLC do Benjamin Wey 40 Wall Street, 38th Floor New York, NY 10005, USA FNL MEDIA LLC do Benjamin Wey 40 Wall Street, 38th Floor New York, NY 10005, USA EFTA01203562