Supporting Documentation · Feb 13, 2025
2325 COM Cover Letter re Zinnia Health Objection w Exs
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Show all pagesand/or delivered without accounting to Plaintiff for same. 5. It would be inequitable if these Defendants were to receive the benefit of the goods sold and delivered and/or the services provided and not be made to account to the Plaintiff for the fair value of goods sold and delivered by Plaintiff. 6. Remuneration has been demanded but has not been made. WHEREFORE, Plaintiff demands judgment against Defendants Zinnia Health, LLC, AW II, LLC doing business as Endeavor House North, LLC, Advanced Health and Education, LLC jointly, severally or in the alternative for the sum of $78,474.31 plus pre-judgment and post judgment contract or legal interest, costs of suit and for whatever further and other relief the court finds appropriate and just. THIRD COUNT BOOK ACCOUNT 1. Plaintiff repeats and realleges the allegations set forth in the preceding paragraphs as if same were set forth at length herein. 2. Plaintiff's books and records reflect that there are monies owed and outstanding by Defendants to Plaintiff. 3. Plaintiff's records establish that there is due from Defendants to Plaintiff Sysco Metro New York, LLC the sum of $78,474.31on a certain book account. 4. Payment of the aforesaid sum has been demanded, but the Defendants have failed to pay same. WHEREFORE, Plaintiff demands judgment against Defendants Zinnia Health, LLC, AW II, LLC doing business as Endeavor House North, LLC and Advanced Health and Education, LLC, jointly, severally or in the alternative for the sum of $78,474.31 plus pre-judgment and post judgment contract or legal interest, costs of suit and for whatever further and other relief the courtBER-L-000272-24 01/16/2024 10:12:07 AM Pg 3 of 5 Trans ID: LCV2024122730
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