INDEX NO. 155982/2019

FILED: NEW YORK COUNTY CLERK 06/17/2019 12:34 PM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 06/17/2019

SUPREME

COURT

COUNTY

OF

OF THE

OF NEW

STATE

YORK

NEW YORK

-------------------------------------------------

KLEIN

SLOWIK,

Index

-X

No.:

PLLC.,

SUMMON_S
Plaintiff,

New
-against-

York

Place

DANIEL

AND

MICHAEL

S. SCHNEIDER,

FARBER,

as the

of Trial

S. FARBER,

AND

SCHNEIDER,

is

County

Designated

LLP

FERRARI,

Plaintiff's

Place

Defendants.

of

Business

------X

TO THE

ABOVE-NAMED
ARE

YOU
a copy
of

your

the

on

after

the

service

is

New

Dated:

for

the

Garden
June

of

this

if

17,

case

relief

City,

if

or,

complete

in

SUMMONED
the

Summons,

this

of

your

demanded

New

to answer

is not

Complaint

exclusive

Summons

failure

in the

is

to

not

appear

Complaint

the

with

served

& CLARK,

FAZIO

BLODNICK,

service

and

York);

default

HEREBY

Answer,

Appearance,

days

by

of

DEFENDANTS:

this

of

the

service

judgment

answer,

within

(or

you

to

serve

to

plaintiff,

delivered

personally

or

of

day

and

action

Summons,

for

attorneys

in this

will

within

30

the

taken

Complaint.

York

2019
Yours

etc.,

FAZIO

BLODNICK,

& CLARK

By:

EDWARD
Attorneys
1325
Garden
(516)

1 of 8

K.
for

Franklin
City,
280-7105

BLODNICK
Plaintiff
Avenue,

New

York

Suite
11530

a Notice

(20)

twenty

within

be

to serve

555

days

after

State

against

of

you

 FILED: NEW YORK COUNTY CLERK 06/17/2019 12:34 PM
NYSCEF DOC. NO. 1

Defendant's

Daniel

RECEIVED NYSCEF: 06/17/2019

Address:

S. Schneider,

Esq.

&

Schneider
Farber,
3rd
630
Avenue,

#601

New

York

York,

New
S. Farber,

Michael

&
#601

New

York

New

&

Schneider
Farber,
3rd
630
Avenue,

#601

New

York

York,

New

Ferrari,

LLP

10017

Esq.

Schneider
Farber,
3rd
Avenue,

630

York,

INDEX NO. 155982/2019

Ferrari,

LLP

10017

Ferrari,

LLP

10017

2 of 8

 INDEX NO. 155982/2019

FILED: NEW YORK COUNTY CLERK 06/17/2019 12:34 PM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 06/17/2019

SÚPREME

COURT

COUNTY

OF

OF THE

STATE

NEW YORK

OF

NEW YORK
Index

----------------X

KLEIN

SLOWIK,

No.:

PLLC,

COMPLAINT

Plaintiff,
-against-

DANIEL
and

MICHAEL

S. SCHNEIDER,

AND

SCHNEIDER

FARBER,

S. FARBER,
FERRARI,

LLP,

Defendants.
-----

--------

Plaintiff,

DANIEL

by

S.

FERRARI,

as and

LLP,

("Klein

York,

attorneys

MICHAEL

Plaintiff

with

for

their

Klein

offices

S.

Verified

Slowik,

located

90

and

FARBER,

Complaiñt,

PLLC,

at

& CLARK,

FAZIO

BLODNICK,

SCHNEIDER,

1.

New

its

X

is a law

Broad

firm

law

to practice

New

602,

AND

as follows:

licensed

Suite

Street,

Defendants

SCHNEIDER

FARBER,

alleges

hereby

of

complaining

in the

New

York,

State

York,

of

10004,

Slowik).

Upon

2.

practice

law

in

the

information

State

and

New

of

belief,

York

and

Daniel

S.

has

an

office

Michael

S.

is an

Schneider

for

the

attorney

practice

of

duly
law

in

licensed

New

to

York

County.

3.

practice

Upon

law

in

the

information

State

and

New

of

belief,

York

and

has

an

office

Farber

for

is

the

an

attorney

practice

of

licensed

duly
law

in

New

is

a law

to

York

County.

Upon

4.

licensed

Farber

to

and

practice

Daniel

information

law

in

S. Schneider

the

and

State

are

belief

of

Farber,

New

members

York

of

said

1

3 of 8

Schneider

and

defendants

law

firm.

and

Ferrari,

Michael

LLP,

Ferrari,

Michael

firm

S.

 INDEX NO. 155982/2019

FILED: NEW YORK COUNTY CLERK 06/17/2019 12:34 PM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 06/17/2019

5.

of Klein

That

and

That

Daniel

client

files

support

Schneider

of

Klein

services

facilities

of

calendar

Slowik,

PLLC

solicited

Ferrari,

LLP;

phone

calls

Klein

Slowik

their

new

assigned

on

a new

consent

or

the

for

are

phone

defendants

PLLC,

addresses

names,

either

Michael

employees

former

logs,

Michael

all

information

billing

records,

and

former

or

S. Farber,

in

contained

electronic

accessed

employees

improper

unethical

and/or

the

records,

the

and/or

and

records

illegal

purposes,

solicited

related

to

PLLC

clients

of

their

(vii)

refused

to

furnish

they

were

although

under

authority

the

name

of

Klein

requested

Slowik,

S.

Schneider

while

employees

(i)

made

in

Klein

unrelated

impending

Klein

Daniel

calls

PLLC

FARBER

and

Slowik

PLLC

of

committed

business

Slowik,

Slowik,

Schneider

Klein

conference

Klein

Klein

to

for

S.

acts:

following

clients

Daniel

of

some

PLLC.

S. Farber

unrelated

for

and

Slowik,

Michael

the

Farber

S.

of Klein

PLLC

Slowik,

them

Slowik,

aforementioned

the

performed

system

(iv)

file

including

defendants

phone

firm;

to

PLLC,

employees

business

not

Klein

to

PLLC

for

Klein

of

access

defendants

PLLC

PLLC

S. Schneider

Daniel

Acts").

That

Slowik,

of

Slowik,

while

acts

had

each

That

9.

and

facilities.

Employee

former

Klein

and

Klein

8.

S. Farber

employees

Slowik,

That

("Former

the

as former

S.

7.

Michael

PLLC.

Slowik,

6.

defendants

PLLC
to

with

to

do

so;

SCHNEIDER

PLLC;

2

4 of 8

for

(ix)

with

(viii)

filed

FERRARI,

removed

kept

the

status

in

without

property

and

of

a log

to

business

Nassau

the

belonging

for

of matters

reports

a motion

(iii)

notification

soliciting

written

Klein

the

business;

(v)
use

Slowik,

Schneider

Farber,

to

as a vehicle

PLLC

Slowik,

firm,

attempted

used

PLLC

correspondence;

(vi)

the

(ii)

Slowik,

new

by

departure

business;

Klein

their

clients

business;

appointments

of

County

knowledge,

to

Klein

 INDEX NO. 155982/2019

FILED: NEW YORK COUNTY CLERK 06/17/2019 12:34 PM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 06/17/2019

Slowik,

PLLC

number

of

Schneider

from

Klein

and

PLLC

Slowik,

That

11.

and

Complaint

without

PLLC

Slowik,

LLP

Ferrari,

from

Farber

office

upon

the

That

website

Daniel

12.

S.

"12"

from

FOR

Farber

and

15.

in

some

through

(x)

(xi)

prepared

Michael

Klein

by

a mass

deleted

PLLC;

documents;

belief

S.

repeats

the

PLLC

Slowik,

Farber,

on

Klein

acts

all

or

said

acts.

FARBER

and

each

the

the

acts

as

and

Daniel

either

set

forth

Schneider

S.

and

Paragraph

in

S.

10 of

the

S. SCHNEIDER

contained

allegation

every
and

Michael

assisted

DEFENDANTS

AGAINST

DANIEL

force

same

defendants

the

ACTION

AND

reiterates

with

of

of

OF

Farber

Ferrari

Michael

some

of

S.

above.

belief

CAUSE

Complaint

the

as set forth

or all

Klein

That

Daniel

S. Schneider

That

damages

of

Salaries

(ii)

Business

(iii)

Value

(iv)

Use

Plaintiff
"15"

of

paid

effect

as if set

forth

Michael

S. Farber

and

Daniel

sustained

damages

due

to

in

Paragraphs

at length

S.

herein.

Schneider

were

of

has

less

of the

but

not

than

the

acts

of

Michael

$500,000.00.

following,

not

others

among

yet

identified:

earned;

stolen;
of

files;

facility

A SECOND

repeats

the

not

consist

(i)

FOR

PLLC

Slowik

Complaint

for

and

CAUSE

reiterates

with

of their

development

AND

the

each

same

and

force

3

5 of 8

own

business.

DEFENDANTS

AGAINST

ACTION

OF

SCHNEIDER

FARBER,

"1"

Slowik,

servants.

AS AND

16.

and

and

and

A FIRST

of the

That

faithless

14.

files

employed

information

Schneider

Plaintiff

13.

of

Klein

still

acts

MICHAEL

those

of

while

information

upon

or benefited

through

electronic

aforementioned

AS AND

"1"

consent

time.

10.

benefited

the

LLP

FERRARI,

every

and

allegation

effect

as if

contained

set forth

in

Paragraphs

at length

herein.

S.

 INDEX NO. 155982/2019

FILED: NEW YORK COUNTY CLERK 06/17/2019 12:34 PM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 06/17/2019

17.

LLP,

That

upon

and/or

collectively

"10"

Paragraph

18.

of

That

than

as a result

$500,000

punitive

costs

damages

and

both

fees,

attorney

assisted

thereof

plaintiff

and

in

and/or

belief

in

in

the

Defendants

conjunction

and/or

Michael

with

benefited

Schneider

Farber,

from

the

and

Farber

and/or

actions

as

not

than

Garden
June

City,
17,

Daniel

S.

forth

in

set

in

demands

the

second

causes

of

together

Plaintiff

with

was

damaged

in

judgment

cause

action

such

action

of

in

a sum

the

first

a sum

of

and

other

in a sum

not

cause

of

less

of

not

than

relief

further

of

less

action

than

less

in

Court

a sum

New

plus

deems

York

2019
etc.

Yours,

FAZIO

BLODNICK,

EDWARD
Attorneys
1325
Garden
(516)

4

6 of 8

K.
for

Franklin
City,
280-7105

& CLARK

BLODNICK
Plaintiffs
Avenue,

New

York

Suite
11530

of

555

not

with

$500,000,

$1,000,000,

as this

$500,000.

proper.

Dated:

Ferrari,

Complaint.

WHEREFORE,
less

or

and

the

and

singularly,

performed

Schneider,

information

interest,

just

and

 INDEX NO. 155982/2019

FILED: NEW YORK COUNTY CLERK 06/17/2019 12:34 PM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 06/17/2019

VERIFICATION
STATE

NEW YORK

OF

)
)ss.:

COUNTY

OF NASSAU

The

under

That

of

record

action

for

and

review

of

the

Dated:

file

and

of

of

New

the

to

beliefs

action

is made

where

by

by

firm

practice

in

of Blodnick,

I have

deponent

deponent's

County

in the

action.

belief,

in this

verification

City,
17,

within

maintained

is outside

Garden
June

the

grounds

This

of business

in

is an ussociate

information

The

admitted

attorney

the

Courts

New

of

York,

oath:

depeilent

Plaintiffs

upon

an

undersigned,

affirms

respectfully

)

this

read

believes

are

Fazio

the

foregoing

the

contents

&

Clark.,

Complaiiit

with

in

attorneys

the

within

to be true.

thereof

communications

the

the

Plaintiff

and

firm.

deponent

affirmant

and

not

by

Plaintiff

maintains

his

EDWA

D K.

because

office.

York

2019

7 of 8

BLODNICK

Plaintiffs'

place

a

 INDEX NO. 155982/2019

FILED: NEW YORK COUNTY CLERK 06/17/2019 12:34 PM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 06/17/2019

Index

COURT

SUPREME

COUNTY
KLEIN

OF

OF THE

STATE

OF

No.

NEW YORK

NEW YORK

SLOWIK,

PLLC.,

Plaintiff,
-against-

DANIEL

AND

S. SCHNEIDER,

FARBER,

MICHAEL

SCHNEIDER,

MICHAEL

S. FARBER,

AND

FERRARI,

LLP.

FERRARI,

Defendants.

SUMMONS

AND

COMPLAINT

FAZIO

BLODNICK,

& CLARK

Attorneys for Plaintif
1325 Franklin Avenue, Suite 555
Garden City, New York 11530
(5 16) 280-7105
(516)
Pursuant
York,

certij?ês

annexed

Dated:

to 22 NYCRR

June

upon

that,

document

I 30-1.1,

are

17, 2019

the

information

undersigned,
and

belief

280-7102

Fax

an attorñêy
reasonable

and

admitted
inquiry,

to practice

in the courts

the contentic-es

coiitaiñsd

not frivolous.

Signature

EDWARD

8 of 8

K.

BLODNICK

of New
in the