FILED: NEW YORK COUNTY CLERK 10/26/2011

EDON71812011

INDEX NO. 107856/2011 RECEIVED NYSCEF: 10/26/2011

NYSCEF DOC. NO. 2

Plaintiff, -against -

Plaintiff designates ,New York County as the place of trial

11107856

REDDY ALLEN, PADMA ALLEN and TECHNODYNE LLC,

Defendants.
____________111______________I__________-----------"-------"---------

SUMMONS
The basis of venue is Plaintiff's place of business: 1633 Broadway New York, New York 10019

To the above named Defendants:

You are hereby summoned to answer the complaint in this action and to serve a copy of your answer, or, if the complaint is not sewed with this summons, to serve a notice of appearance, on the Plaintiffs Attorneys within twenty (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 upon your failure to answer, judgment will be taken against you for by default for the relief demanded in the complaint.

Dated: New York, New York July 7,201 1

1633 Broadway New York, New York 10019 (212) 506-1700

TO:

Reddy Allen 6 Little Place Wayne, New Jersey 07470 Padma Allen 6 Little Place Wayne, New Jersey 07470

FIL
Technodyne LLC JU1 0 1 2011 6 Little Place r rCLERK'S OFFICE Wayne, New Jersey 07470 m~v (Serve Secretary of State) NEW YQRK

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-against-

Plaintiff,

COMPLAINT

E D D Y ALLEN, PADMA ALLEN and TECHNODYNE LLC,

complaining of the defendants, Reddy Allen, Padma Allen and Technodyne LLC ("Technodyne") (collectively, "Defendants"), respectfully alleges, upon information and belief,

as follows:
AS AND FOR A FIRST CAUSE OF ACTION
1.

At all times hereafter mentioned, KBT&F, a limited liability partnership

organized and existing under the laws of the State of New York, was doing and transacting business in the County, City and State of New York and did maintain an office located at 1633 Broadway, New York, New York 10019.

2.

At all times hereinafter mentioned, defendant Reddy Allen was and is an

individual residing at 6 Little Place, Wayne, New Jersey 07470.

3.

At all times hereinafter mentioned, defendant Padma Allen was and is an

individual residing at 6 Little Place, Wayne, New Jersey 07470.

4.

At all times hereinafter mentioned, defendant Technodyne was and is a New

ih Jersey corporation duly authorized to do business in the State of New York wt a principal
office located at 6 Little Place, Wayne, New Jersey 07470.

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5.

By written retainer agreement dated December 16, 20 10 (the Allen Retainer

Agreement), defendants Reddy Allen and Padma Allen retained Plaintiff for the purpose of providing professional legal services.
6.

By written retainer agreement dated December 20, 2010 (the Technodyne

Retainer Agreement), defendant Technodyne retained Plaintiff for the purpose of providing professional legal services.

7.

Commencing on or about December 16, 2010, pursuant to the Allen Retainer

Agreement and the Technodyne Retainer Agreement (collectively, the Retainer Agreements), Plaintiff, at Defendants specific request, performed professional legal services and generated expenses and disbursements attendant thereto, all for the benefit of Defendants, which services were accepted by Defendants without objection or rejection. 8. The services rendered by Plaintiff to Defendants were contracted for and were

substantially performed in the City, County and State of New York pursuant to the Retainer Agreements at an agreed price as reflected in the Retainer Agreements, which was negotiated between the parties as being fair and reasonable. 9. Defendants agreed to pay Plaintiff the sums of monies representing those

usually and customarily charged by Plaintiff, as well as all expenses incurred, the unpaid portion
of which totals $366,703.98.

10.

Plaintiff has performed each and every obligation under the Retainer

Agreement between the parties.

11.

Despite demands for payment, there still remains outstanding and due Plaintiff

from Defendants the s u m of $366,703.98.

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12.

By reason of the foregoing breach of contract, Plaintiff has been damaged in

the sum of $366,703.98. 13.

As the amount in controversy exceeds $50,000.00, there is no jurisdiction for

arbitration pursuant to Part 137 of the Rules of the Chief Administrator of the Courts of the State of New York.
AS AND FOR A SECOND CAUSE OF ACTION
14.

Plaintiff repeats, reiterates and realleges each and every allegation contained in

the first cause of action with the same force and effect as though more fully set forth at length herein. 15. The fair and reasonable value of the services rendered by Plaintiff to or on

behalf of Defendants at the Defendants specific request commencing on or about December 16,

2010 that remains unpaid is $366,703.98.

16. Despite requests for payment, there remains due and owing to Plaintiff from

Defendants the sum of $366,703.98.

17.

By reason of the foregoing, and pursuant to the theory of quantum meruit,

Plaintiff has been damaged in the sum of $366,703.98.

AS AND FOR A THIRD CAUSE OF ACTION

18.

Plaintiff repeats, reiterates and realleges each and every allegation contained in

the first two causes of action with the same force and effect as though more fully set forth at length herein. 19. Commencing on or about December 16, 2010 and periodically thereafter,

Plaintiff rendered to the Defendants invoices for services rendered and expenses generated, all of which invoices, at the time sent, were received by Defendants without rejection or objection.
3

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20.

By reason of the foregoing, Defendants are liable to plaintiff on the theory of

account stated in the amount of $366,703.98.

WHEmFORE, Plaintiff demands judgment against Defendants on each of the three

causes of action in the amount of $366,703.98 together with interest, costs and reasonable attorney's fees. Dated: New York, New York July 7,201 1

New York, New York 10019 (2 12) 506- 1700

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I-

'
ALL-STATE LEGALS
07181-BF

.UIlBZ-BL 071RR ( r V . 07184-WH 000 722 0510 WYNY aslegal SrM"

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SlJPfiEME COURI' O F THE STATE OF NEW YORK COUNTY OF NEW YORK

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KASOWI'I'Z, BENSON, TORRES & FRIEDMAN, LLP,

Plaintiff.

- against KEDDY AI.I.EN, PADMA ALLEN and TECHNODYNE, I,l,C,

SUMMONS AND COMPLAINT

KASC)WITZ, T~ENSON.TORRKS FRIEDMANP & ILL Attorrieyy(.r) for PI ai titi ff

1633 BROADWAY NEW YORK NEW YORK 10019
212 506-1700
,-

-."..,I

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Pursuant to 22 NYCRR 130-1.1-a, the undersigned, a n attorn,e+y ndinitted to practice in the courts oflveu) York State, certifies that, upon informatioii and belirf arid reasonable irrquiry, (1) th.e corr.tentions oonlained in the annexed document are not frivolous and that (2) i f thc anmexed document is an initiutirg pleudin,g, (i) the mutter was not nsiblr fiw the illegal conduct are i f th,e rnatter involves potential not participating in th.e matter or shuring in any fee earned 1 olainrs for personal iiqjury or wrongful denth, the mnttrr wns n

July ................... 201 1 Dated: ....................... 7.?,

Signature .....................

............................

Bated:

_PLEASE TAKh' NCI7'IC:E

~ l ^ l " -

Ai,to.vn(?y(.qj &for.

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