FILED: NEW YORK COUNTY CLERK 07/16/2024 02:24 PM INDEX NO.

156470/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/17/2024

SUPREME COURT OF THE CITY OF NEW YORK

COUNTY OF NEW YORK
---------------------------------x
Index No.
Manchanda Law Office And Associates
PLLC,

Plaintiff, SUMMONS

-against-
Defendants’s Business Address:
250 Parke Avenue, 7th Floor
Anthony Seepersad, Dwayne Grant, New York, NY 10177
Nichelle Abney, Jessica Plusko,
Regus, Mark Dixon,

Defendants.
The basis of the venue is the
Defendant place of business
----------------------------------x

To the Above-named Defendants:

YOU ARE HEREBY SUMMONED to appear in the Supreme Court of the City
of New York, County of New York at the office of the said court at 60
Centre Street, New York, New York, 10007, in the County of New York,
within the time provided by the law as noted below and to file your
answer to the annexed complaint with the Clerk; upon your failure to
answer, judgment will be taken against you together with the costs of
this action.
Dated: New York, New York
July 16, 2024 _______________________
Manchanda Law Office & Asso PLLC
By: Rahul Manchanda, Esq.
_____________________ 270 Victory Boulevard
Anthony Seepersad New Rochelle, New York 10804
250 Park Avenue, 7th Floor Tel: (212) 968-8600
New York, NY 10177 Fax: (212) 968-8601

NOTE: The law provides that (a) if this summons is served by its
delivery to you personally within the City of New York, you must appear
and answer within TWENTY (20) days after such service; or
(b) if this summons is served by delivery to any person other than
you personally, or is served outside the City of New York, or by
publication, or by any means other than personal delivery to you within
the City of New York, you are allowed THIRTY (30) days after proof of
service thereof is filed with the Clerk of the Court within which to
appear and answer.

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SUPREME COURT OF THE CITY OF NEW YORK

COUNTY OF NEW YORK
------------------------------------x
Manchanda Law Office And Associates
PLLC,

Plaintiff, COMPLAINT

-against-
Index No.

Anthony Seepersad, Dwayne Grant,

Nichelle Abney, Jessica Plusko,
Regus, Mark Dixon,

Defendants.
------------------------------------x
Plaintiffs, Manchanda Law Office And Associates PLLC and Rahul

Manchanda, for its complaint against defendants Anthony Seepersad, Dwayne

Grant, Nichelle Abney, Jessica Plusko, Regus, and Mark Dixon, alleges:

1. Plaintiff, at all times relevant hereto, was and is a law firm located

at 270 Victory Boulevard, New Rochelle NY 10804, who provides legal

services.

2. Defendants Anthony Seepersad, Dwayne Grant, Nichelle Abney, Jessica

Plusko, Regus, and Mark Dixon, are a virtual office network which also

provides physical addresses to their customers all around the world.

3. For weeks and months before formal execution and payment on multiple

contracts for physical and virtual office spaces at Regus Centers

located at 250 Park Avenue, 7th Floor, New York NY 10177 and at 173

Huguenot Street, Suite 200, New Rochelle NY 10801, Plaintiff and

Defendant Jessica Plusko hammered out written and verbal contract

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negotiations including but not limited to the detailed protocol of how

Regus personnel would handle and process incoming new and current

clients of the law firm moving forward after Plaintiff moved into the

spaces.

4. Almost immediately contracts were signed and fully paid by Plaintiff,

Co-Defendant Dwayne Grant, a rogue employee at Regus Park Avenue

location, emailed to Plaintiff that he refused to follow said protocol,

specifically that he would not follow the directions previously agreed

to by and between Plaintiff and Co-Defendant Jessica Plusko.

5. Additionally, Plaintiff also discovered that his Google Business Ads,

a source where he secures 99% of his new clients, would not accept an

address change until and unless Plaintiff had “physical office space

that he could video tape,” a fact known to Defendants, but unknown to

Plaintiff.

6. When Plaintiff complained about the above issues, Defendant Jessica

Plusko feigned ignorance and sociopathic indifference, telling Plaintiff

that he could “always purchase physical office space” and thus be given

a key, whereupon he could “film himself opening his office,” and this

verify his Google Business address change.

7. Feeling coerced, pressured, blackmailed, extorted, stressed, and

crunched for time, Plaintiff reluctantly signed a contract under duress

to purchase this additional physical office in order to get his Google

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Address change “verified” so that his ads could properly function again

(eg, none of his photographs are visible).

8. Soon thereafter, however, “City Manager” Anthony Seepersad intervened

and declared to Plaintiff, that he would not honor the new physical

office contract and that “Jessica Plusko would handle that,” but even

mre egregiously, that he would also not honor Plaintiff and Defendant

Jessica Plusko’s negotiated for, bargained for exchange for good

consideration, and not process new incoming clients in the specific way

and manner previously agreed to by and between Plaintiff and Defendant

Jessica Plusko, thus potentially costing Plaintiff hundreds of thousands

of dollars in financial losses per month.

9. Even though Plaintiff filed complaints with the NYS Attorney General,

NYC Department of Consumer Affairs, Federal Trade Commission, Better

Business Bureau, and other agencies, Regus, Anthony Seepersad, Jessica

Plusko, Nichelle Abney, Dwayne Grant, Mark Dixon would not budge, and

basically told the Plaintiff to pound sand.

10. Plaintiff is now left without office space, without clients, without

income, and without peace.

AS AND FOR A FIRST CAUSE OF ACTION AGAINST DEFENDANT

11. Plaintiff repeats and realleges each and every allegation contained in

paragraphs 1 through 10 of this Complaint.

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12. Therefore, in accordance with the above, Plaintiff seeks a judgment

against Defendants personally and professionally for breach of contract

with actual and punitive damages in the amount of $10,000,000, with the

exact amount to be calculated at trial.

AS AND FOR A SECOND CAUSE OF ACTION AGAINST DEFENDANT

13. Plaintiff repeats and realleges each and every allegation contained in

paragraphs 1 through 10 of this Complaint.

14. Therefore, in accordance with the above, Plaintiff seeks a judgment

against Defendants personally and professionally for fraudulent

inducement to contract with actual and punitive damages in the amount

of $10,000,000, with the exact amount to be calculated at trial.

AS AND FOR A THIRD CAUSE OF ACTION AGAINST DEFENDANT

15. Plaintiff repeats and realleges each and every allegation contained in

paragraphs 1 through 10 of this Complaint.

16. Therefore, in accordance with the above, Plaintiff seeks a judgment

against Defendants personally and professionally for fraudulent

misrepresentation with actual and punitive damages in the amount of

$10,000,000, with the exact amount to be calculated at trial.

AS AND FOR A FOURTH CAUSE OF ACTION AGAINST DEFENDANT

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17. Plaintiff repeats and realleges each and every allegation contained in

paragraphs 1 through 10 of this Complaint.

18. Therefore, in accordance with the above, Plaintiff seeks a judgment

against Defendants personally and professionally for tortious

interference with contracts with actual and punitive damages in the

amount of $10,000,000, with the exact amount to be calculated at trial.

AS AND FOR A FIFTH CAUSE OF ACTION AGAINST DEFENDANTS

19. Plaintiff repeats and realleges each and every allegation contained in

paragraphs 1 through 10 of this Complaint.

20. Therefore, in accordance with the above, Plaintiff seeks a judgment

against Defendants personally and professionally for detrimental

reliance with actual and punitive damages in the amount of $10,000,000,

with the exact amount to be calculated at trial.

WHEREFORE, Plaintiff requests a judgment against Defendants as follows:

a. On the first cause of action, a judgment declaring that Defendants

have committed breach of contract against the Plaintiff.

b. On the second cause of action, a judgment declaring that Defendants

have committed fraudulent inducement to contract against the Plaintiff.

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c. On the third cause of action, a judgment declaring that the

Defendants have committed fraudulent misrepresentation against Plaintiff.

d. On the fourth cause of action, a judgment declaring that the

Defendants have committed tortious interference with contract against

Plaintiff.

e. On the fifth cause of action, a judgment declaring that the

Defendants have committed detrimental reliance against Plaintiffs.

f. A permanent injunction against Defendants restraining them from

evicting or removing Plaintiff from his contracted and fully paid for 2

office spaces, or continuing the above described torts, and any other such

further relief as the Court deems just and proper, including applicable

interest, costs, and disbursements of this action.

Dated: New York, NY

July 16, 2024

________________________
Manchanda Law Office And Associates PLLC
By: Rahul Manchanda, Esq.
270 Victory Boulevard
New Rochelle, NY 10804
Tel: (212) 968-8600
Fax: (212) 968-8601

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