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FILED: NEW YORK COUNTY CLERK 06/04/2021 06:46 PM INDEX NO. 653623/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/04/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ------------------------------------------------------------------X CRAIG J. MARSHAK, Index No.: EMIL ASSENTATO SUMMONS Plaintiffs Plaintiff designates New v. York County as the venue for trial based DIMAS LAW GROUP, P.C., upon the residence of JERELYN CREUTZ, SHR VENTURES LLC, and the defendants per STANLEY HUTTON RUMBOUGH CPLR § 503 Defendants ------------------------------------------------------------------X TO: Dimas Law Group 370 Lexington Avenue, Suite 505 New York, NY 10017 Jerelyn Creutz 17525 Rancho Del Rio Rancho Santa Fe, CA 92067 SHR Ventures LLC 370 Lexington Avenue, Suite 505 New York, NY 10017 Stanley Hutton Rumbough 14 Andrews Road Greenwich, CT 06830 TO THE ABOVE NAMED DEFENDANTS: YOU ARE HEREBY SUMMONED to answer the Complaint in this action and to serve a copy of your answer on plaintiffs’ attorney within 20 days after service of this summons, exclusive of the day of service, or within 30 days after service is complete if this summons is not personally delivered to you within the State of New York. In case of your failure to answer, judgment will be taken against you by default for the relief demanded in the Complaint. 1 of 18 FILED: NEW YORK COUNTY CLERK 06/04/2021 06:46 PM INDEX NO. 653623/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/04/2021 Dated: New York, New York June 4, 2021 GUZOV, LLC By: _____________________ Debra J. Guzov, Esq. David J. Kaplan, Esq. Attorneys for Plaintiffs 805 Third Avenue, 8th Floor New York, New York 10022 (212) 371-8008 2 of 18 FILED: NEW YORK COUNTY CLERK 06/04/2021 06:46 PM INDEX NO. 653623/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/04/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK -----------------------------------------------------------------------X CRAIG J. MARSHAK and EMIL ASSENTATO, Index No. Plaintiffs COMPLAINT v. DIMAS LAW GROUP, P.C., JERELYN CREUTZ, SHR VENTURES LLC, and STANLEY HUTTON RUMBOUGH Defendants ________________________________________________X Plaintiffs Craig J. Marshak and Emil Assentato, by and through their counsel Guzov LLC, as and for their complaint against Defendants Dimas Law Group, P.C. (“Dimas Law”), Jerelyn Creutz (“Creutz”), SHR Ventures LLC (“SHR”), and Stanley Hutton Rumbough (“Rumbough”), state as follows: SUMMARY OF THIS ACTION 1. This case arises from Defendants’ wrongful attempts to pressure Plaintiff Craig J. Marshak into surrendering shares in a valuable African mining venture by denying and withholding payment for past contracted business consulting services unless and until he agreed to surrender his shares. 2. Defendants each individually and collectively then conspired to cause Rumbough to withhold compensation due and owing to Plaintiff Marshak for past services rendered pursuant to the August 2020 Agreement and the Domain Name Transfer Agreement (each as defined below). 3. As a result, Defendant Rumbough has breached the August 2020 Agreement and the Domain Name Transfer Agreement. Dimas Law, Creutz and Rumbough have each tortiously 1 3 of 18 FILED: NEW YORK COUNTY CLERK 06/04/2021 06:46 PM INDEX NO. 653623/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/04/2021 interfered with both Plaintiffs’ contracts and prospective economic relations, and are therefore liable to Plaintiffs in an amount to be proven at trial but believed to be in excess of $100 million ($100,000,000.00). PARTIES 4. Plaintiff Craig J. Marshak is an individual whose permanent address is 36 Moshe Sheret Street, Tel Aviv, Israel, and whose residence in this State is 1385 Park Street, Atlantic Beach, NY, 11509. 5. Plaintiff Emil Assentato is a resident of New York State with the address of 146 Piping Rock Road, Locust Valley Long Island, New York. 6. Defendant Dimas Law Group (“Dimas Law”) is a Professional Corporation organized and existing under the laws of the State of New York, with offices located at 370 Lexington Avenue, Suite 505, New York, N.Y. 10017. 7. Defendant Jerelyn Creutz is a resident of San Diego, California, and holds herself out as a member (a licensed attorney) of Dimas Law. On information and belief, Creutz has not graduated from law school and is not a member of the bar of any state. Creutz is also an officer of defendant SHR Ventures. 8. Defendant SHR Ventures is a limited liability corporation organized and existing under the laws of the State of New York with its principal offices at 370 Lexington Avenue, Suite 505, 10017. 9. Defendant Stanley Hutton Rumbough is a resident of Greenwich, Connecticut, whose address is: 14 Andrews Road Greenwich Ct, 06830. Rumbough is the sole principal of SHR Ventures. The manager of SHR Ventures is Defendant Creutz. 2 4 of 18 FILED: NEW YORK COUNTY CLERK 06/04/2021 06:46 PM INDEX NO. 653623/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/04/2021 JURISDICTION AND VENUE 10. The relief sought in this action exceeds the minimum amount required for subject- matter jurisdiction in this Court. 11. This Court has personal jurisdiction over defendants Dimas Law and SHR Ventures based upon their presence within the State of New York. 12. This Court has personal jurisdiction over Defendants Creutz and Rumbough based upon those individuals’ transaction of business within this State, and/or upon their commission of tortious activities outside this State which caused injury in this State, where Creutz and Rumbough each engaged in persistent courses of conduct directed at this State from which they each derived substantial income. 13. In the alternative, each of the Defendants were participants in a common conspiracy whereby each of them performed one or more overt acts intended to deprive Plaintiff of his compensation, or force Plaintiff by improper means to renounce his valuable interest in an African mining venture. As such, it is proper for the jurisdictional contacts of each member of the conspiracy to be attributed to every other member. 14. Venue is proper in this judicial district based upon the residences of one or more defendants. STATEMENT OF UNDERLYING FACTS 3 5 of 18 FILED: NEW YORK COUNTY CLERK 06/04/2021 06:46 PM INDEX NO. 653623/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/04/2021 15. Plaintiff Craig J. Marshak is an experienced investment banker and financial professional with decades of experience and a proven track record in sourcing, evaluating and closing deals. 16. Plaintiff Craig J. Marshak is a graduate Summa Cum Laude and Phi Beta Kappa of Duke University and Harvard Law School and had a one-year scholarship to the London School of Economics in England. His career on Wall Street has spanned decades of experience at such notable firms as Morgan Stanley, Wertheim & Company, Wertheim Schroder, Schroders, and Nomura Securities in London, England. Mr. Marshak is shown as the Co-Founder and Vice Chairman of the Moringa SPAC, trading on NASDAQ under the symbol MACAU, which raised and closed on $115 million of funding in the month of February of 2021. 17. Mr. Marshak’s record of accomplishments on Wall Street is set out in his biography for the Moringa SPAC, including his identifying the first-round investment into CYBER ARK, a company trading today on NASDAQ at a circa $5 billion valuation, and his identifying the first-round investment of SHOPPING.COM, a company sold to EBAY for some $600 million. 18. Mr. Marshak does not have any record whatsoever of any disciplinary history with the USA regulatory bodies of FNRA or the Securities Exchange Commission (SEC). 19. Mr. Rumbough was in fact so impressed with Mr. Marshak’s personal background that Mr. Marshak was selected as an Independent Director for his OTC listed company HUTN, which had re-branded from EF Hutton America. 20. Plaintiff Marshak has a longstanding working association with Plaintiff Emil Assentato, the Chairman and CEO of Nukkleus, a publicly traded company. Marshak sits on the Board of Directors of Nukkleus. Emil Assentato and Craig J. Marshak were asked by Defendant 4 6 of 18 FILED: NEW YORK COUNTY CLERK 06/04/2021 06:46 PM INDEX NO. 653623/2021 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/04/2021 Rumbough to employ Aahan Menon, a gentleman residing jointly with Mr. Rumbough’s daughter in Manhattan, and they did so. 21. In exchange for Plaintiff Assentato’s agreement to employ Mr. Menon, Marshak agreed to share 50% of his equity interest in the Geiya Mining transaction (described below) with Mr. Assentato. 22. Defendant Stanley Hutton Rumbough (“Rumbough”) is a scion of the well-known Hutton family. His grandfather, Edward Francis Hutton, was the founder of EF Hutton. 23. Plaintiff Craig Marshak was introduced to Stanley Hutton Rumbough sometime in the period of 2014 to 2016 when Mr. Rumbough was the Chairman of EF Hutton America, and a certain gentleman named Christopher Daniels was the Chief Executive Officer. Mr. Daniels at the time was seeking investment funds into EF Hutton America, and also to list the company on the USA OTC stock market. Mr. Marshak was introduced as a potential independent Board Member for EF Hutton America. 24. After that, in early 2019, Mr. Rumbough was in telephone contact with Mr. Marshak and requested that Mr. Marshak provide consulting services to correct errors made by his prior advisors, which had by that time cost Mr. Rumbough over $10 million of personal cash investments and losses. These services were to be in connection with finding a new potential owner and acquirer for the brand rights of EF Hutton, the restructuring of the old EF Hutton America, known as HUTN on the OTC stock market, and the identification of a new series of investments for the Rumbough family offices in other related sectors in the financial services arena.