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INBOUND FAX TRANSMISSION ATTACHED H Scanned By Date TO: DATE DELIVERED: TIME REC'D: 71/3 TOTAL PAGES: BY: EFTA01125926 04/0812014 14:33 (FAX) P.001/008 LAVELLE LAW, Ll 501 Vast Cm= STREET PALATINE, ILLINOIS 60067 www.laveUelavAcom TELEPHONE: 8474705-7555 FACSIMILE: 847-705-9960 KERRY XIS/MLR TIMOTHY M. HUMUls THEODORA! M. MCGINN IvIATTHIVII I. &multi CAIARRON R MONn AMILALICAss HEATHER G. WALSER STEVEN A. MICALA ICELIYA.ANDEnSoli Inas Et VOICT ANNITER & BURT JAWS IL Dow% per G. PIQUERO LANCE C. Zranatt Jaestua A. NSS$6R Marrs', B. Rica. BRIAN I.WARENS (bum-tont L Ihnsimesia Henn A. SCHUSTER • TELECOPIER COVER LETTER • FILE No. (a) 6355 DATE: 4.8.14 TO: Andrew K. Carruthers FAX NO.: (618) 656-1364 TO: FAX NO.: CC: FAX NO.: CC: FAX NO.: FROM: Lavelle Law, Ltd. — Timothy Hughes RE: TOTAL NUMBER OF PAGES:8 ORIGINAL TO FOLLOW: DESC_RIECION/SPE LCIAL INSTRUCTIONS 41;To follow please find a Notice of Emergency Modell Adverse Claim to Citation pertaining to case number 13 MR 1617. 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(847) 7054555 TELECOPIER NUMBER: (847) 705-9960 ruiterrillaArAtUCC0veume EFTA01125927 04/08/2014 14:33 P.002/008 IN THE CIRCUIT OF THE NINETEENTH JUDICIAL CIRCUIT LAKE COUNTY, ILLINOIS Jeffrey Epstein and L.S.J., LLC ) Plaintiffs, ) ) v. ) Case Number: 13 MR 1617 ) Nick Lambros and AVLC, LLC d/b/a ) Sound X ) Defendants ) and ) ) American Chartered Bank, 1199 E. Higgins ) Road, Schaumburg, IL 60173 ) Garnishee. ) NOTICE OF EMERGENCY MOTION ADVERSE CLAIM TO CITATION To: Andrew K. Carruthers 130 N. Main St., P.O. Box 510 Edwardsville, IL 62025 Facsimile 618-656-1364 acarruthers@hepl erbroom.com act @heplerbroom.com PLEASE TAKE NOTICE that on April 10, 2014, at 1:30 p.m„ or as soon thereafter as I may be heard, I shall appear before the Honorable Judge Simonian or any judge sitting in his stead in Courtroom 306, at 18 North County Street, Waukegan, Illinois, 60085, and shall then and there present the attached Emergency Motion Adverse Claim to Garnishment Summons, a copy of which hJyceby served upon you. Timothy M. Hughes 6208982 Lavelle Law, Ltd. 501 West Colfax St. Palatine, Illinois 60067 (847) 705-7555 CERTIFICATE OF SERVICE 1, Timothy M. Hughes, an attorney, certify that I served a copy of the foregoing document to each person to whom it is directed at their respective addresses by hand delivery or by depositing a copy in the United States Mail at 440 W. Colfax, Palatine, IL 60067 postage pre-paid, on April 8, 2014, before the hour of 5:00 p.m. and via facsimile and email to the addresses above. Page of 3 EFTA01125928 P.0031008 04/08/2014 14:33 IN THE CIRCUIT OF THE NINETEENTH JUDICIAL CIRCUIT LAKE COUNTY, ILLINOIS Jeffrey Epstein and L.S.J., LLC ) Plaintiffs, ) ) v. ) Case Number: 13 MR 1617 ) Nick Lambros and AVLC, LLC d/b/a ) Sound X ) Defendants ) and ) ) American Chartered Bank, 1199 E. Higgins ) Road, Schaumburg, IL 60173 ) Garnishee. ) Emergency Motion Chien° Audio Video Design Corvoratlon's Adverse Claim to Garnishment Summons NOW COMES the adverse claimant, Chicago Audio Video Design Corporation ("CAVD"), by and through its attorneys, Lavelle Law, Ltd., and for its Adverse Claim to the Garnishment Summons of Jeffrey Epstein and L.S.J., LLC directed towards the CAVD' American Chartered Bank account states and alleges as follows: 1. Plaintiff has a judgment against Nick Lambros and AVLC, LLC d/b/a Sound X and does not have a judgment claim against Chicago Audio Video Design Corporation cVb/a Sound X. 2. Plaintiff brought a Non-Wage Garnishment Summons preceding against Nick Lambros and AVLC, LLC d/b/a Sound X to American Chartered Bank the Third Party Garnishee, which is in possession of Account Number XXXI 374 an account belonging to the CAVD ("CAVD Acct # 1374"). 3. Adverse claimant, CAVD added the Defendant/Judgment Debtor, Nick Lambros, as an authorized signer to their CAVD Acct # 1374 as a convenience for the CAVD. 4. American Chartered Bank in response to Plaintiff's Garnishment Summons has frozen the account CAVD Acct #1374. Page 2 of 3 EFTA01125929 04/08/2014 14:33 P.004/008 5. The CAVD Acct #1374 is only titled in Chicago Audio Video Design Corporation d/b/a Sound X name alone and is not and never was property of either Nick Lambros or AVLC, LLC cVb/a Sound X. 6. Chicago Audio Video Design Corporation obtained the assumed name Sound X from the Illinois Secretary of State on August 27, 2010 (See Group Exhibit A). Upon information and belief AVLC, LLC use of the assumed name Sound X in Illinois was revoked on or about January 9, 2009 (See Exhibit B). 7. The CAVD Acct #1374 does not belonging to either Judgment Debtor. Therefore, the funds should be released immediately to the CAVE). WHEREFORE, the adverse claimant, Chicago Audio Video Design Corporation respectfully requests the following relief: A. That this Court enters an order releasing the funds in the CAVE) Met # 1374 to the CAVD; B. That this Court award Chicago Audio Video Design Corporation their bank charges incurred because of the plaintiffs citation; C. That this Court award Chicago Audio Video Design Corporation their reasonable attorneys' fees and litigation expenses; and D. That this Court award any other relief this Court deems just and proper. Timothy M. Hughes Lavelle Law, Ltd. 27743 501 West Colfax St. Palatine 111 67 Respectfully Submitted, Chicago Audio Video Design Corporation d/b/a Sound X By: One of it SA62514500\ 6355WitatIon \ Emergency Motion Obi to Citation.cloc Page 3 of 3 EFTA01125930 04/08/2014 14:34 (FAX) P.0051008 rage 1 or i CORPORATION FILE DETAIL REPOR7' [Entity Nome Statue Entity Typo CHICAGO AUDIO VIDEO DESIGN CORPORATION File Number 01612512 __JI /cm[CORPORATION IIncorporation Date 1 (Demesne) Agent Name 00/0512001 SUSAN L DAWSON Agent Street Addree WM ALGONQUIN RD STE 30:31 [Agent City Agent Zlp Annual Report Piling Date Assumed Name Old Corp Name agjaralagafr eaggEgmea FROLU43—MEADOWS 00006 00112/2013 Type of Corp 1 DOMESTIC ECA Mate I (ILLINOIS Agent Change Gate H 0420/2012 PruldaM Name i Address Secretary Nemo & Address DurntIon Data F0rYoar JOHN BRANSKY 950 W NORTHWEST HWY BARRINGTON R60010 SAME PERPMAL 2013 INACTIVE • AURORA SYSTEMS INACTIVE • CHICAGO AUDIO VIDEO DESIGN ACTIVE - SOUND X 00/27/2010 • NORTHERN SKY SATELLITE CORPORATION `Purchase Certificate of Good Standing (One Certificate per Transaction) SACK TO HOME PAGE EXHIBIT iq hap://www.ilsos.govicorporatelic/CorporateLlcController 1/17/2014 EFTA01125931 04/08/2014 14:34 P.006/008 rage I of 1 Date y.0 FILE DETAIL REPORT SWay Name Status EllEtY Type File Date JESSE WEITE SECRETARY OF STATE File Number 01572044 REVOKED On I01/00/2000 -J I u.c Type of LLC Foreign Agent Name Agent street Address Agent City F°712°I2M—11-Jurisdiction [-FT. MYRON N. GOLDSTEIN 770 FRONTAGE RD.. GTE. 103 NOwnrrieLO I eagent Zip I BOOBS Annual Report Fling 1100/00/0000 Assumed Name [Sedge Name nAgent Change Date 07/2M0 —ocoa Principal Orrice Management Type Duran For Year 3069 S.E. OUANSIT CIRCLE STUART, FL MOW MGR Ziff PERPETUAL 2008 INACTIVE- SOUND X NOT AUTHORGED TO ESTABUSH SERIFS Return to the Search Screen BACK TO NOME PAGE Exi-nert / hap://www.i Isos.govicorporatel Ic/CorporateLleControl ler I/16/91)1d EFTA01125932 04/0812014 14:34 TAY) P.0071008 IN THE CIRCUIT OF THE NINETEENTH JUDICIAL CIRCUIT LAKE COUNTY, ILLINOIS Jeffrey Epstein and L.S.J., LLC ) Plaintiffs, ) ) v. ) Case Number: 13 MR 1617 ) Nick Lambros and AVLC, LLC ) Sound X ) Defendants ) and ) ) American Chartered Bank, 1199 E. Higgins ) Road, Schaumburg, IL 60173 ) Garnishee. ) Affidavit of John Bromic's, I, John Bransky, being first duly sworn on oath depose and state as follows: 1. I am of legal age and each of the statements herein is true and correct and known to me of my own personal knowledge. If called as a witness, I could and would competently testify thereto. 2. I am the President and Secretary of Chicago Audio Video Design Corporation d/b/a Sound X ("CAVD"). 3. CAVD is the co-owner of a checking account at American Chartered Bank account #: XXX1374. 4. The above American Chartered Bank account was opened only in the name of CAVD and has never had any other party on title to the account at any time. 5. Nick Lambros is an authorized signer on the CAVD American Chartered Bank account XXX1374, however he is not nor never was on title to that or any CAVA bank account. 6. Nick Lambros is not a shareholder of CAVA and is only an employee of CAVD. 7. On or about August 27, 2010, CAVD's application to the Illinois Secretary of State for an assumed name "Sound X" was granted. 8. The garnishment summons served on American Chartered Bank has frozen our account XXX1374 with $11,930.80, which frozen funds has created a hardship on CAVD in Page 1 of 2 EFTA01125933 04/08/2014 14:34 P.0081008 being able to meet its current accounts payables and payroll, as well as, the impact with vendors on accounts payable checks outstanding. 9. The frozen CAVD funds at American Chartered Bank need to be released immediately in order for CAVD to continue to be able to meet its current accounts payables and payroll obligations. 10. CADV was not a part to the above captioned lawsuit es upon information and belief it involved one of our employees and a Florida LLC. 11. Further Affiant sayeth not. Subscribed and sworn to before me on April 8, 2014 Notary Public Document prepared by: Timothy M. Hughes Lavelle Law, Ltd. 501 West Colfax St. 60067 Attorney Number: 27743 SA6251-6500 63551CitailoMaffidavit John Bransky 4.08 14 doc Page 2 of 2 John Bransky EFTA01125934