v2Affirmation in Support of Motion to Quash-Stay Action

FILED: NEW YORK COUNTY CLERK 01/30/2018 11:25 PM INDEX NO. 650779/2016

NYSCEF DOC. NO. 63 RECEIVED NYSCEF: 01/30/2018

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Court of the State of New York, heldOVF.'PgoVF.t.

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HON. ARLENE P. BLUTHPRESENT: HON.

Justice of the Supreme Court +54-+54-

TAP~ ~index Number

[fill in name(s)] Plaintiff(s)QQ- against - '

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VAtt C>a Ec DY BEM /fiAt L¼ ORDER TO SHOW CAUSE24 F2Q 6 A4 4 P- DLP A4+f4/// &4//tWC IN ClVIL ACTION

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Upon reading and filing the affidavit(s) of 4-, WDs,Do a& a . [yourname(s)], swam to on , 20

[date Affidavit in Support notarized], and upon the exhibits attached to the affidavit,

[ldentify Exhibits below. List additional Exhibits on separate page.]

Exhi itExhibit A-A- ' 'n d4 6'IP )) +> V//trV//g

Let the party or attorney in opposition show cause at 1.A.S. Part ,~,~, Roorn ~OLf+,

of this Court. to be held at the Courthouse, 60 Centre Street, New York, N.Y., on the day .

~ at 1 Q Û clock In the & noon~noon ores soon as such party or

may be heard why an order should not be made, providing the following relief:

[briefly describe what you are asking the Court to do]: t/creqÓ-4 Î-t 4 u u ·nW¼

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añidavit in support, and all other papers upon which this order is granted, upon all other arties to

this sewn or their attomeys, who have

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appeared in this action, on edii feFe the ~ da of

be deemed good and sufficient An affidavit or other proof of

semice shall be presented to this Court on the return date directed in the second paragraph of this

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ENTER

ARLENE P BLUTH

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4 At 1.A.S. Part - of the Supreme

:a4 Court of the State of New York, held

in and for the County of NewYork at

the Courthouse therefore, 60 Centre

Street, New York, N.Y., on the

day of , 200___

PRESENT: HON.

Justice of the Suprerne Court

TA'~ v i index Number

[fill in name(s)] Plaintiff(s)- against - '

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IQ!tEA6%DY BEduT /}74 L¾ ORDER TO SHOW CAUSE/2 4 F2r2 MM 41 &DLL' fdAf4A't St441/2Yam IN CIVll ACTION

[fill in narryli(s)] )frgg+~ p ( ~ Defendants(s)

Upon reading and filing the affidavit(s) of ((c a-,do Do 3o~Å/llCla Å(p. Drb . d A1 (your name(s)], swum to on A 3 A V , 20 ,

[date Affidavit in Support notarized], and upon the exhibits attached to the affidavit,

Ildentify Exhibits below. List additional Exhibits on separate page.]

E>>hibitA- ' ''> f PQH»> k'< I Z V/lg

Let the party or attorney in opposition show cause at I.A.S. Part , Room

of this Court, to be held at the Courthouse, 60 Centre Street, New York, N.Y., on the day of

, 200 ____ at clock in the noon or as soon as such party or

may be heard why an order should not be made, providing the following relief:

1what you are the Court to do]: u><(briefly describe asking

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for the reasons that [briefly describe the reasons why you should be granted what you are

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Sufficient cause appearing therefore, let personal service of a copy of this order the

affidavit in support, and all other papers upon which this order is granted, upon all other parties to

this action or their attorneys, who have appeared in this action, on or before the day of

, 200_ be deemed good and sufficient. An affidavit or other proof of

service shall be presented to this Court on the return date directed in the second paragraph of this

order.

ENTER

J. S. C.

OSCAct4-06OSCAct446 22



(" Thomas"

FILED : NEW YORK COUNTY CLERK 05/31/ 2017 12 : 13 PM)INDEX NO. 65O779/2O16

NYSCEF POC. NO. 24 . RECEIVED NYSCEF: 05/31/2017

SUPREME COURT OF THE STATE OF NEW YORKCOUNTY OF NEW YORK---------..---------------------....------------...-------

JAMES W. THOMAS II,

Plaintiff,

-against- . Index No. 650779-2016

KAREN'S BODY BEAUTIFUL LLC, RAFIQKALAM ID-DIN, DAMANI SAUNDERSON and . JUDGMENTKAREN TAPPIN, .. '

Defendants.---------------------------..----------.......---------.-.......-

Plaintiff James W. Thomas II ("Thomas") having moved this Court pursuant to

CPLR 3215 for a default judgment against defendants Karen's Body Beautiful LLC,

Rafiq Kalam Id-Din, Damani Saunderson and Karen Tappin (individually and

collectively, "Defendants");"Defendants" Defendants having failed to oppose Thomas'

motion;

Honorable Robert R. Reed by Order dated February 21, 2017 and entered on February

22, 2017 having granted Thomas' motion for a default judgment against all Defendants

and directing an inquest for the assessment of damages; the issue of damages having been

tried before the Honorable Martin Schoenfeld on May 2, 2017; and the Decision and

Order of Honorable Martin Schoenfeld dated and entered May 17, 2017 awarding

Thomas judgment against all Defendants jointly and severally in the amount of

$167,691.00 with interest commencing on January 15, 2016 and $11,655.00 with interest

commencing on the date of entry of judgment and directing the Clerk of the Court to

enter judgment accordingly;

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FILED : NEW YORK COUNTY CLERK 05/31/2017 12 : 13 PldINDEX NO. 650779/2016

NYSCEF pOC. NO. 24 RECEIVED NYSCEF: 05/31/2017

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NOW, upon motion of Greenberg Freeman LLP, attorneysI

for Thomas, it is

hereby

ADJUDGED, that James W. Thomas II, 88 Lenox Co , Piscataway, New Jersey

08854 shall have judgment against and recover jointly and se erally from (a) Karen's

Body Beautiful LLC 220 36thStreet, Unit 606, Brooklyn, New York

11282; (b) Rafiq Kalam Id-Din,

, 616 Quincy Street, 3 dFloor, Brooklyn, NY 11221; (c) Damani

Saunderson 220 36*Street, Unit A606, Bróoklyn, New York 11282;

and (d) Karen Tappin, 220 36thStreet, Unit A606, Brooklyn, 1 ew York 11282, the sums

of $167,691.00 with interest at 9% per um qpqp said amountamount'amount' from January 15, 2016 in

the amount of $ o s 1 55.00 together wit , the costs and

disburs as taxed by the Clerk, makin a total of $20tp826; andifoi%28;,."iloi'M28'-:

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FILED: NEW YORK COUNTY CLERK 05/31/2017 12:13 PM|INDEX NO. 6 5 0 77 9/2 01 6

NY SCE F DOC . NO. 24 RECE IVED NY SCE F: 05/31/2017

SUPREME COURT OF THE STATE OF NEW YOJ(KCOUNTY OF NEW YORK

.7XiGEsiffñõüXiii"-"---"-----"-----""----JAMES W. THOMAS llPlaintiff, index No. 650779-2016

againstBill of Costs

Kamn's Body Beautiful LLC, et al.Defendant.

Costs as a htCost before Note of Issue,CPLR 8201(1) . Index o. ce PLR 801 a)Costsafter Note of lssue, CPLR 8201(2 Referees'Fee,CPLR 8301(a)(I)(, 8003(a)Trial ofIssue, CPLR 820 l(3) jjtt(Qg@f ~ Q

Comrnissioners'Compensation,CPLR 8301(a)(2)Real Property Actions CPLR 302(a)(b Clerk's fee for lis pendens,attachment,CPLR 8021(a)(1)Mortgage Foreclosure CPLR 8302(d) Entering and Docketing Judgment,CPLR 8301(a)(7)

Paid for seachesCPLR 8301(a)(10)Court Allowed Costs Affidavit A AnknwledemeyMSI R 20

Motion CostsCPLR 8202 Serving S.(tm rs)Qf)$ : y)Mortgage Foreclosure, CPLR 8303(a)(I) Requestfur judicial interetiâñ S95-00Difficult or Extraordinary Case,CPLR 8303(a)(2) Note of issueCPLR 8020(a) S30.00Partition of real property, CPLR 8303(a)(3) Paid referee'sreport CPLR 8301(a)(12)Fiduciary will/trust construction CPLR 8303(a)(4) Certified copiesof papersCPLR 8301(a)(4)DIsposition of infant Property CPLR 8303(a)(5) Satisfaction piece CPLR 5020(a)Motion to Enforce Judgment CPLR 8303(b) Transcripts and filing CPLR 8021Costsand Sanctions CPLR 8303-a, Rule 130.1 Certified copy ofjudgment CPLR 8021

PostageCPLR 8301(a)(12)Appeal Costs Jury FeeCPLR 8020[c]

Appeal to Appellate Term, CPLR 8203(a)Stenographers'FeesCPLR 8002, 8301(a)(9)

Appeal to Appellate Division CPLR 8203(b) Sheriti's feeson execution CPLR 8011, 8012Appeal to Court of Appeals CPLR 8204 Sheriti's fees,attachment,arrest,etc. CPLR 8011

Paid printing expensesCPLR 8301(a)(6)Clerks FeesCourt of Appeals CPLR 8301(a)(12)Paid copies of papersCPLR 8016(a)(4)Motion ExpensesCPLR 8301(b) $45.00Feesfor Publication CPLR 8301(a)(3)Serving SubpeonaCPLR 8011(b), 830l(d)Paid for searchCPLR 8301(a)(1I)Referee'sReportAttendance of witness CPLR 8001(a)(b)(c), 8301(a)(1)

Total Costs 7 00 S seeree OtherTotal Disbursernents SSQ S -980-00'

Totat Costsand Disbursments STheundersigned,an attorney duly admitted to practice law in this State, affirms under penalty ofperjury that the above costsand

were or will be actually andnecessarily incurred and am reasonablein amount.GREE FREEMAN LLP

Dated: New York, New York By:

May 17, 2017 Sanford H. GreenbergEast 59th Street, Fl. 22

New York, NY 10022gy 2Q O C (212) 838-9738

S D Attorneys for PlaintiW

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FILED : NEW YORK COUNTY CLERK 05/31/2017 12 : 13 PMINDEX NO. 650779/2016

NY,SCEF DOC. NO. 24 RECEIVED NYSCEF: 05/31/2017

THISISAN E-FILED CASE

ALL DOCUMWNT$ AtUSÝ

-gg MLBD ELECTRONICALLY.

GREENBERG FREEMAN LLP

By: s/ Sanford H. Greenberg

Sanford H. Greenberg

110 East59th

Street'

22ndFlOOr

New York, New·York 10022

(212) 838-9738

Attorneys for Plaintiff James W. Thomas II

FILED ANDDOCKETED

nar 5 1 asAT / 2 UL Ê MN#.,00.GUCSQWlG

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SUPREME COURT OF THE STATE OF NEW YORKCOUNTY OF NEW YORK

JAMES W. THOMAS II

AFFIDAVIT IN SUPPORT(Names of Plaintiff(s) Of Order to Show Cause

vs to Vacate a Default Judgment

KAREN'S BODY BEAUTIFUL LLC,

RAFlQ KALAM ID-DIN, DAMANI SAUNDERSON, KAREN TAPPIN

Index No. 650779-2016

(Names of Defendant(s)-------...--..---------..---..---------..--------------

STATE OF NEW YORKCOUNTY OF K+N68 lvN, ss:

(County where notarized)

RAFIQ R. KALAM ID-DIN II , being duly sworn, deposes and says:(Insert your name)

1. I am the defendant in this action.

2. I reside at: 751 PUTNAM AVENUE, 3RD FL, BROOKLYN NY I 1221(Street address, city, state. zip code)

3. That this is an action for: VACATE DEFAULT JUDGMENT(Describe type of action)

4. That on the _ 22- day of February , 2017 , a default judgment was

entered by this court.

5. That the defendant did not appear / answer because: improper service: notice of summons

and complaint were never provided to any of the defendants, nor to anyone in their households or

places of business.

(State reason)

6. That your defendant has a meritorious defense for the following reasons.



'

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4

1. Plaintiff was never employed by the defendants Rafiq Kalam Id-Din, Damani Saunderson, Karen Tappin(State the facts which support your defense & attach any supporting papers you may have, use additional paper if necessary.)in their personal capacities. nor does the Plaintiff assert that he was ever employed by the defendants

Rafiq Kalam Id-Din, Damani Saunderson, Karen Tappin in their personal capacities.

2. Plaintiff never had any employment agreement with Karen's Body Beautiful LLC.

3. Plaintiff voluntaril y discontinued his relationship with Karen's Body Beautiful LLC before any agreement

ran equity stake in the LLC could be finalized,f'

and sh noel im for breach of contract (see attached).

4. Plaintiff's attempt to attach personal assets of defendants Rafiq Kalam Id-Din, Damani Saunderson,.Karen

Tappin is improper, and should have been limited to the assets corporate LLC entity only.

7. No previous application has been made for the relief sought herein.

WHEREFORE, I respectfully request an order vacating the judgment or such further

relief as the Court may find to be just and proper.

(S your name in the presencehtary Public)

State of New York Ced(haA ( ŽCounty of New York

(Print you na )

Sworn to before me this

day of /%7Gr . , 20

Notary Public

Benjarnin Steinberg

Notary Public, State of New York

No. 028T6042665

Qualified in Bronx CountyCommission Expires May 30, 20_ _6

22



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CIVIL COURT OF THE CITY OF NEW YORKCOUNTY OF NEW Y ORK : PART_____________________________

JAMES W. THOMAS 11

Plaintiff, AFFIDAVIT IN SUPPORT

-against- index No. 650779-2016

KAREN'S BODY BEAUTIFUL LLC,

Defendant.

RAFIQ K Al .A M_ID-DIN,-DAMANLSAUNDERSON,

KAREN TAPPIN

STATE OF NEW YORKCOUNTY OF MINGS N ss.:

RAFIQ KALAM ID-DIN a being duly sworn, hereby deposes and says:

Dafiq 1(alam id-Din II, harahy danacac and says

1. I am Rafiq R. Kalam Id-Din II, General Counsel and shareholder of Karen's Body Beautiful LLC,located at 4014 ist venue, suite (us, , urooiayn n y i az2i.

2. I submit this affidavit in support of defendants' Order to Show Cause to Vacate Default Judgment.

3. I submit this affidavit based on personal knowledge.

4. I hereby assert and affirm that I have never been given or served any legal documentation related to

isma-

5. I hereby assert and affirm that to the best of my knowledge I have never met nor interacted in anyway with I ingn Ranchey nr anyone in the employ of, or affiliated with Keating & er AttorneyService Inc.

6. I hereby assert and attest that I have never entered into any agreement, employment or otherwise withIne MainurT JameS W. 1 homas 11 m my personal capacity, , nor on oenati of Naren S nouy neautltulLLC.

7 I hereby assert that my nersonal hank accoimt has heen held and restrained by IPMorgan Chase atthe behest of the Plaintiff and his representatives as a result of the default judgement levied against the

Court when such judgment should have been properly limited only to assets and accounts of thecorporateI en



R I hereby accert that the TPMaronn f'hace hanic nernunt held and rectrainerl at the hehest nf the

Plaintiff and his representatives is my personal account, from which I take care of my foster son and

hóuocheld, and inic vvhiol> us g40ccods f van, aci assets Of dic dcf©ndanc oóipeiate onuty Kàncub DudyBeautiful LLC have ever been deposited or held.

9. I understand that the Plaintiff was granted a default judgment in this matter based on the assertionthat notice summons and complaint intended for me and other defendants was provided to Nilda Arias,Carol Simpson and Damani Saunderson on multiple occasions, and each of whom have asserted and

affinnied diat uc such ñóï¡cc Gi doctuscrdadûñ vvcic cic, pióvided to dicru at any tinic. Gi vce the

aforementioned attestations I request that the default judgment entered against the Defendants be

vacated, and that any holds, restraints and/or other encumbrances on the J organ ase bank account

in my name, as well as any other such personal bank accounts of Rafiq Kalam ld-Din, Damani

Saunderson and Karen Tappin be immediately stayed, released and/or vacated as the case may be.

10. I 3tatc and a33cyt thc fcycgoing undcr pcñalty of perjury.

WHEREFORE, THE RSIGNED RESPECTFULLY REQUESTS THE WITHIN

MOTION BE TED.

S nature

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Sworn to before me this day of 20_Û

Notary Public/Court EniployeeBenjamin Steinterg

Notary Public, State of New York

No. 02ST6042685Qualified in Bronx County

Commission Expires May 30,20

CIV-GP-121-i

FREEClVIL COURT FORMNo feemaybechargedto fill in this form.

Formcanbe foundat: tt,'/www nvcourt ov!courts/ vc civil/f rms shtml.



CIVIL COURT OF THE CITY OF NEW YORKCOUNTY OF NEW Y ORK : PART_____________________________

JAMES W. THOMAS II


-against- Index No. 650779-2016

KAREN'S BODY BEAUTIFUL, RAFIQ KALAt

Defendant._____________________________

STATE OF NEW YORKCOUNTY OF KINGS ss.:

NILDA ARIAS , being duly sworn, hereby deposes and says:

Nilda Arias, hereby deposes and says:

1. I am Nilda Arias, Executive Officer of Ember Charter School (formerly TFOA-Professional Prep

2. I submit this affidavit in support of defendants' Order to Show Cause.


4. I hereby assert and affirm that I have never been given or served any legal documentation related tothis matter.

way with Lingo Sanchez or anyone in the employ of, or affiliated with Keating & Walker Attorney



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.

6. I understand that the Plaintiff and their representatives have asserted that I had previously been givendocumentation related to this matter by them or their representatives, on multiple occasions, all of

which I unequivocally deny. .

7. I understand that the Plaintiff was granted a default judgment in this matter based on the assertion

affirm is not true, and thus I support the Defendants' request that the default judgment be vacated and

set aside.

R I state and assert the foregning under penalty of perjury

WHEREFORE, THE UNDERSIGNED RESPECTFULLY REQUESTS THE WITHIN

MOTION BE GRANTED.

Signature

Swom to before me this day of f/A 20

MARK A. KERRNotary P,ublic/Court Employee NOTARY PUBLIC-STATE OF NEW YORK

No. OlKE6272068Qualified in Kings County

My Commission Explres November 13, 202O

ClV-GP-12N

FREEClVIL COURT FORMNo feemaybechargedto fill in this form.

Formcanbe found at: htt llwww n c urts ovlc rts tnclciviilform shtmi,



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CIVIL COURT OF THE CITY OF NEW YORKCOUNTY OF NEW YORK : PART

_____________________________

JAMES W. THOMAS II



KAREN'S BODY BEAUTIFUL, RAFIQKALAl'

Defendant._____________________________

STATE OF NEW YORKCOUNTY OF KINGS ss.:

Carol Simpson , being duly sworn, hereby deposes and says:

Carol Simpson, hereby deposes and says:

1. I am Carol Simpson, previously an employee of Karen's Body Beautiful LLC, located at 4014 Ist

Aversc, Su;tc 703, 1Drocklyn NY 11232.




way with Lingo Sanchez or anyone in the employ of, or affiliated with Keating & Walker AttorneyI



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6. I understand that the Plaintiff and their representatives have asserted that I had previously been given

documentation related to this matter by them or their representatives, on multiple occasions, all or


7. I understand that the Plaintiff was granted a default judgment in this matter based on the assertion

affirm is not true, and thus I support the Defendants' request that the defaultjudgment be vacated and

set aside.

R I state and assert the foregning under penalty of perjury

WH EFOR , THE UNDERSIGNED RESPECTFULLY REQUESTS THE WITHIN

M ON B RAN E .

/ . .

Signature

Sworn to before me this day of 4 2d3

Notary Public/Court EmployeeMARK A. KERR

NOTARY PUBLIC-STATE OF NEW YORKNo. 01KE6272068

Qualified In Kings CountyMy Commission Expires November 13, 202 0

CtVÓP-121-i

FREECIVlL COURT FORMNo feemaybechargedto fill in this form.

canForm befoundat: hit,'iwvvn nvcou ovlcourtsrn:crcivitrf rms hti il.



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CIVIL COURT OF THE CITY OF NEW YORK ,COUNTY OF NEW YORK : PART

JAMES W. THOMAS II .



KAREN'S BODY BEAUTIFUL, RAFIQ KALAl

Defendant.____________________________

STATE OF NEW YORKCOUNTY.OF KINGS ss.:

Damani Saunderson , being duly sworn, hereby deposes and says:

Damani Saunderson, hereby deposes and says:

1. I am Damani Saunderson, Co-founder and COO of Karen's Body Beautiful LLC, located at 4014 1st

Avenue, Guitc 703, 7TDróoklyn NY 11232.




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way with Lingo Sanchez or anyone in the employ of, or affiliated with Keating & Walker Attorney .

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6. I understand that the Plaintiff and their representatives have asserted that I had previously been givendocumentation related to this matter by them or their representatives, on multiple occasions, all of


7. I understand that the Plaintiff was granted a default judgment in this matter based on the assertion-assett-and--

affirm is not true, and thus I support the Defendants' request that the default judgment be vacated and

set aside.

R I state and assert the foregoing 1mder penal ty of perjury

WHEREFORE, THE UNDERSIGNED RESPECTFULLY REQUESTS THE WITHIN

MOTION BE GRANTED.

Signature

Sworn to before me this 3 day of 20

o//n AvSt GAUNA FEDMANNotary Public, State of NewMNk

Notary Public/Court Employee No. 01FE6051186Qualified in Kings County

Commission Expires November 20, 2018

ClV-GP-121-i

FREE CIVIL COURT FORMNo fec may bechargedto fill in this form.

Fonn canbefound at: http://www.nycoutts.gov/couns/nyc/civil/furms.shttn1.



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â€” â€”â€”

Gmail - Your Resignation 8/3/17, 5:54 PM

M Gmail Rafiq Kalam Id-Din <[email protected]>

-- .._ _ __

Your Resignation2 messages

Rafiq Kalam ld-Din <[email protected]> Thu, Feb 4, 2016 at 1:30 PMTo: [email protected], Jim Thomas <[email protected]>

Cc: Karen Tappin <[email protected]>, Karen Tappin <[email protected]>, Damani

Saunderson <[email protected]>

Jim,

Please be advised that effective January 25, 2016, Karen's Body Beautiful, LLC (KBB) has accepted your resignation

proffered on January 15, 2016 and are hereby discontinuing ourbusiness relationship with you for breach of contract.

On January 15, 2016 you indicaladin sifiemail to CEO Karen Tappin and COO Damani Saunderson that you were

resigning, "suspending all work 9n,çKB , a clear and unequivocal breach of your agreement with KBB to serve as the

CFO of KBB until such time as the organization decided otherwise, in exchange for 5% of the Djeneba company'savailable shares upon issuance.

Please return all work productr and proprietaryr r information to Karen and Damani asap I (including all hard copy,vielectronic and digital formats), and provide us with receipts and/or invoices for any outstanding expenses and/orexpenditures not yet reimbursed. Upon receipt of all work product and proprietary information, and review of submittedreceipts and/or invoices, KBB will provide payment for such expenses and/or expenditures it deems reasonable andappropriate.

Finally, please consider this notice to cease and desist all communications involving and/or on behalf of KBB with anythird parties, including but not limited to NYBDC, Forefront Wealth Management, First Choice, Olla, etc. Any further

communication by you, your agents or assigns, directly or indirectly involving and/or on behalf of KBB will beconsidered fraudulent and tortious, subject to any and all appropriate remedies under the law.

Please feel free to contact me directly with any questions.

Regards,

Rafiq

Rafiq R. Kalam Id-Din II, Esq.General CounselKaren's Body Beautiful, LLC917-536-2493

Karen Tappin <[email protected]> Sun, Feb 7, 2016 at 2:24 AMTo: Rafiq Kalam ld-Din <[email protected]>

Cc: Damani Saunderson <[email protected]>

Rafiq, we haven't heard the last from him. I suspect he's digging through his emails, building a case for something oranother. Anyways, can you create a response to Gordon?[Quoted text hidden)

Karen Tappin

Beauty Boss

https://mail.google.corn/mail/u/0/?ui 2/kik 2744c81d548jsver 1Kuk...th 152ba9egdb22d5d18siml 152adgd23b4087t8&simt 152bagegdb22d5d1https://mail.google.corn/mail/u/0/?ui=2&ik=2744c61d54&jsver=tKuk...th=152ba9e9db22d5d1&siml=t52ad8d23b4087f6&siml=152ba9e9db22d5d1 Page1ofPage 1 22of

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Gmail - Your Resignation 8/3/17, 5:54 PM

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Karen's Body Beautiful

718.797.4808www.karensbodybeautiful.com

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8/3/2017 Gmail - RE: Position

M Gmail Karen Tappin <[email protected]>

RE: Position

1 message

Jim Thomas <[email protected]> Fri, Jan 22, 2016 at 10:39 AMTo: Karen Tappin <[email protected]>Cc: Damani Saunderson <[email protected]>, Rafiq Kalam Id-Din <[email protected]>

Karen,

I iteed to darify my position with respect toKSB. As I mentioned before I have suspended allwork concerning KBB

urttil l have a document detailing my shares in the company. This suspension of work also covers any meetings. I can'tcan'

continue to spend personal funds withouta clarification of my ownership.

I also don't understand what there is to talk about on this issue. This matter was settled for me with your email of Oct

22, 2015. Because of my respect for you as a person, I considered your word as gospel since you are the CEO of the

company.

At this point the 5% is non-negotiable. So given that, can we resolve this and remove this from the agenda? If there

are other items to be discussed at the meeting that I need to be involved in, please let me know what they are.

I hoped you didn't change the meeting on my account, as I have other project meetings set for Monday and Tuesday.

I await your reply/decision about my share document.

Best Regards,

James W. Thomas II (Jim)

Chief Financial Officer

Administrative Office # 732-968-6300

Cell # 908-334-2801

From: Karen Tappin [mailto:[email protected]]Sent: Thursday, January 21, 2016 5:27 PMTo: Jim Thomas <[email protected]>

Cc: Damani Saunderson <[email protected]>; Rafiq Kalam Id-Din <[email protected]>Subject: Re: data for balance sheet

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Mr. Thomas, re going to meet on Monday at 5:30pm at Rafiq's school.

616 Quincy St, 3rd flr

Brooklyn, NY 11221

On Wed, Jan 20, 2016 at 1:14 PM, Jim Thomas <[email protected]> wrote:

Karen,

,' I mentioned this to you before that I have a standing meeting each Sunday that usually last all day so I can't make

the meeting on any Sunday.

Best Regards,

W. Thomas II (Jim)


.. Administrative Office # 732-968-6300

I Cell # 908-334-2801

tI From: Karen Tappin [mailto:[email protected]]

Sent: Wednesday, January 20, 2016 1:05 PM

To: Jim Thomas <[email protected]>' Cc: Damani Saunderson <[email protected]>; Bill Solli <[email protected]>

. Subject: Re: data for balance sheet

: Mr. Thomas, we'll discuss this matter on Sunday.

,I Sent from my iPhone

On Jan 20, 2010, at 8:07 AM, Jim Thomas <[email protected]> wrote:

!Karen,

tI'm going to have to disagree with you about the timeframe. Please see below:

1) Oct 22, 2015 Karen and Damani offered 5% which I accepted. I waited for a document to this effectuntil January 4, 2016

I2) On January

4th I requested a doc and you said you would provide a doc.

3) January 8, I asked again. At that time I asked if there was a problem and you said there was none.You stated you would be working on it over the weekend.

4) On January13th I asked again and you said I would have something by Friday January

15th15'".

5) On January13th you wrote back "the new entity isn't organized yet. I'm awaiting for an update on

that, so I'll let you know in the upcoming days when it's done."

6) On the conference call on January 14th, you told Gordon the new entity had been formed.

https://mail.googie.corn/mail/u/0/?ui=2&ik=65cb52e5dc&jsver=bbsv5zgiMgE.en.&view=pt&as from=jim%40karensbcdybeautifukcom&as sizeoperator=s

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7) January15th I suspended work. It seemed like I was getting the run around.

I

8) Today is January 20 and still nothing. I am only requesting a document stating what you have

already indicated in your email on Oct 22, 2015.

Below is something that I was expecting which should not take that long to do:

1, Karen Tappin, CEO and President of Karen's Body Beautiful, LLC hereby/grants James W. Thomas IIfive percent shares in Karen's Body Beautiful, LLC or any organization that Karen's Body Beautifultransitioned into. These share are for accounting working preformed during the time period September 1thru December 31, 2015 as the company's CFO and are not revocable. When the new company is fullyformed, actual stock certificates can be provided at that time.

This document should be notarized and signed by both Karen and Damani.t

I don't understand the holdup. This is a business agreement based upon me providing a business

service. I have worked on the company's business since early September 2015. I have spent mypersonal funds to travel to New York and to Charlotte, NC.

t

I would like to get past this as soon as possible as there is a lot more work to be done but I need a

simple document from you.

Best Regards,

James W. Thomas II (Jim)1

IChief Financial Officer


Cell # 908-334-2801I

From: Karen Tappin [mailto:[email protected]]Sent: Saturday, January 16, 2016 12:58 PM

To: [email protected]


Subject: Re: data for balance sheet

Mr. Thomas, actually it's disappointing that you are choosing to"suspend"

working on KBB, which onlyhurts the company. Your request is only a week old, I informed you several times that I was working on itand re at our most critical point in the survival of the company. There's a lot going on; in the pastweek, Judy resigned, Lavaisa, our Brand Manager is returning to college today, Nastacia is being trainedto assume Judy's position and I have my regular tasks to take care of. When Damani returns fromBarbados on Monday, he'll review the doc and I'll send it to you.

tSent from my iPhone

On Jan 15, 2016, at 9:50 AM, Jim Thomas <[email protected]> wrote:

Karen,

I briefly looked at the data and saw that it was incomplete and needs work. And yes Idid not send Carol the payroll sheets.

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!I have to say I am disappointed that I have asked several times for the share doc and to

date have not received it. I therefore am suspending all work on KBB until we have anapproved doc in place.

I hope you understand but this is just business.

Best Regards,



!!Administrative Office # 732-968-6300

Cell # 908-334-2801

!IFrom: Karen Tappin [mailto:[email protected]]Sent: Friday, January 15, 2016 9:27 AM

To: Jim Thomas <[email protected]>



Mr. Thomas, on yesterday's call, you said that I didn't send you all the data you needed tomove forward. I sent you the requested items, except for item #3 because you never sentCarol the payroll sheet she asked you for a few days ago, so she could complete that item.

On Sat, Jan 9, 2016 at 9:45 AM, Karen Tappin <[email protected]> wrote:.

Saunderson- $10K/$40K to be paid in January, the balance as soon as we can.Interest TBD. Sobel- $417/$5000 paid to date, 3% interest, 1 year term.

I

Sent from my iPhone

:; On Jan 9, 2016, at 8:52 AM, Jim Thomas <[email protected]> wrote:

What are the terms for each loan:

1) Repayment time?

2) Repayment amount?

3) Interest Rate?

4) Activity, le have you repaid any of these?

r

Best Regards,It

James W. Thomas ll (Jim)I

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8/3/2017 Gmail - RE: Position1,



Cell # 908-334-2801

From: Karen Tappin [mailto:[email protected]]Sent: Saturday, January 9, 2016 7:37 AMTo: Jim Thomas <[email protected]>



l!

#1 Attached.#6- Zachary Saunderson: $10K in November + $30K in December, DeniseSobel: $5K

rf

!On Fri, Jan 8, 2016 at 8:17 PM, Karen Tappin <[email protected]>wrote:I

,i Obviously, ignore all the statements I sent, was an error.i; #5 attached.

1' On Fri, Jan 8, 2016 at 8:01 PM, Jim Thomas:,: <[email protected]> wrote:

1Best Regards,



l Administrative Office # 732-968-6300

Cell # 908-334-2801

From: Karen Tappin [mailto:[email protected]]Sent: Friday, January 8, 2016 7:31 PM

! !II

To: Jim Thomas <[email protected]>Cc: Damani Saunderson <[email protected]>Subject: Re: data for balance sheet

1- I'm waiting for an assistant to filter the data.

4 and 5- are you referring to the attached document?

!

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i On Fri, Jan 8, 2016 at 6:54 PM, Karen Tappin<[email protected]> wrote:

!

On Fri, Jan 8, 2016 at 12:57 AM, Karen Tappin

; <[email protected]> wrote:

Correction, Carol is doing 2-3, I'll have 1, 4 and 5 donetomorrow.

IOn Fri, Jan 8, 2016 at 12:52 AM, Karen Tappin

!, I <[email protected]> wrote:

Carol is working on 1-3, I'll have 4 and 5 done tomorrow. I'll

I have info about the loans tomorrow.

! i!

On Wed, Jan 6, 2016 at 8:03 PM, Jim Thomas<[email protected]> wrote:

!l l

! Karen,

For the balance sheet: I need a complete list of all the

equipment owned by KBB. You should include every! I

'single item in the warehouse. The higher the amount of

assets the lower the negative retained earnings.

Currently that number is ($70,213) . I would like to see a

lower number here.

For the income statements:

1) PayPal-1 need to know how much was spent and for

I what business purposes for all of 2015

', 2) I need the sales for November and December to be

entered on the 2015 sales analysis. I attached the Oct

, YTD sheet

I 3) Payroll-December Hours worked by employee.! !

I Please add to the payroll spreadsheet attached.

! 4) Citibank data-See column U. Please identify all the

money in this column. This is November YTD

! li. We

need to add December activityI to this spreadsheet. Please

I download

5) Payroll-We need to reconcile the amount in columnM with the actual payroll spreadsheet by month.

6) Date of all loans you received in November &December.

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8/3/2017 Gmail-RE:Position

If you want, you can supply the payroll information and

; I'llI' input.

Also if you will download the Citibank data and send to! me I'llI' add it to the spreadsheet. I'll then give it back to

I, you to determine the correct columns. Once I have all

this back and I reconcile the data from the landlord we

should just about have everything we need to generate

a 2015 Income statement.

!

!

Let chat if you have any questions at all.




; Cell # 908-334-2801

From: Karen Tappin [mailto:[email protected]]: Sent: Wednesday, January 6, 2016 7:09 PM

: To: Jim Thomas <[email protected]>

:': Cc: Damani Saunderson <[email protected]>


Mr. Thomas, what data are you missing from me?

!

On Wed, Dec 23, 2015 at 3:31 PM, Jim Thomas

! :::.<[email protected]> wrote:

Rafiq,

See below:

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8/3/2017 Gmail -RE:PositionRE: Position

Best Regards,



Adminstrative Office # 732-968-6300

Cell # 908-334-2801

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Karen Tappin

Beauty Boss

Karen's Body Beautiful718.797.4808

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Beauty Boss


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8/3/2017 Gmail - Conferencecall

G«a

GmalimmaiI Karen Tappin <[email protected]>

Conference call

8 messages

Jim Thomas <[email protected]> Thu, Oct 22, 2015 at 11:22 AMTo: Karen Tappin <karentappin@gmailcom>

Karen,

I need to plan my day. When did you want to do a conference call and who would be on the call? Do we really need acall? Why not just email what it is you have to chat about? It might save some time.

Best Regards,




Cell # 908-334-2801

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Karen Tappin <[email protected]> Thu, Oct22, 2015 atÅÔTo: Jim Thomas <[email protected]>Cc: Damani Saunderson <[email protected]>Bcc: "[email protected]" <[email protected]>

Mg.'Mr. Thomas .Regarding your stake, Damani and I have decided to offer you a firm 5% We think 5% would be fair since you recentlyjoined KBB and you haven't invested any cash in the company. When re financially able, all four of us willtake a

addition to our points.

Also, about your ask for a temporary salary, unfortunately we won't be able to do it. Right now, as it is, we struggle tomake payroll every week and we pay the factory staff, later and later, almost every week. On a few occasions, Carol haseven advanced payroll out of her own savings. Damani and I have been suffering it out since he resigned in 2012 andhe's still continuing to invest his pension in the business.

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aren Tappin

Beauty Boss


Jim Thomas .conP Thu, Oct 22, 2015 at 12:22 PMTo: Karen Tappin <karentappinggmail.cone

.Cc: DamaniSaunderson <[email protected]>,ist;ë!ë‡M-

„':::„-..'..â€”.: ': - --3yt÷ë#Amn

Karen/Damani,

I understand andthanks for the offer of 5%. I could live with that. Unfortunately as 1 mentioned before, I had a

window to Work on this and that window is closing. That is part of the reason I was pushing so hard to get the data to

me. I now have to move on to a paying situation. I'rp ri@tupset with you guys, it Just that I can't afford to continue to

for no pay. I'm sure you can understand that. Let's discuss how I can give you.what I have worked on so maybe

someone else can complete the work.

I would mention one item that I disagree with. I have worked on this project for about 7 weeks without pay which

does equate to cash in the business.

Let me know when you have time to chat so we can review where we stand with the financials. We can spend some

time chatting about each step and what else needs to be done.

I've enjoyed working on this and wish you guys every success.

Best Regards,




Cell # 908-334-2801

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From: Karen Tappin [mailto:[email protected])Sent: Thursday, October 22, 2015 11:30 AM

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Subject: Re: Conference call

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Karen Tappin <[email protected]> Thu, Oct 22, 2015 at 1:09 PMTo: Rafiq Kalam Id-Din <[email protected]>

When can you meet?

Sent from my iPhone

Begin forwarded message:

From: "Jim Thomas" <[email protected]>

Date: October 22, 2015 at 12:22:20 PM EDTTo: '"Karen Tappin"' <[email protected]>Cc: "'Damani Saunderson'"

<[email protected]>, <josephiné@karensbc·dybe=ütifutcom>" '

Subject: RE: Conference call

[Oacted te×t rudden)

_ - - __ _

Karen Tappin <[email protected]> Thu, Oct 22, 2015 at 6:20 PMTo: Jim Thomas <[email protected]>

Cc: Damani Saunderson <[email protected]>, josephine@karensbc-dybsâütifüI.com'hal â€”: Lt&ciutiiul.corn

Mr. Thomas, are you available to meet on Saturday at Panera at 11am?

Sent from my iPhone

On Oct 22, 2015, at 12:22 PM, Jim Thomas <[email protected]> wrote:

Karen/Damani,

I understand and thanks for the offer of 5%. I could live with that. Unfortunately as I mentioned before, I

had a window to work on this and that window is closing. That is part of the reason I was pushing so

hard to get the data to me. I now have to move on to a paying situation. I'm not upset with you guys, it

just that I can't afford to continue to work for no pay. I'm sure you can understand that. Let's discuss

how I can give you what I have worked on so maybe someone else can complete the work.

I would mention one item that I disagree with. I have worked on this project for about 7 weeks without

pay which does equate to cash in the business.

Let me know when you have time to chat so we can review where we stand with the financials. We canspend some time chatting about each step and what else needs to be done.

I've enjoyed working on this and wish you guys every success.

Best Regards,

W. Thomas II (Jim)

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From: Karen Tappin [mailto:[email protected]]Sent: Thursday, October 22, 2015 11:30 AM




Mr. Thomas,Regarding your stake, Damani and I have decided to offer you a firm 5%. We think 5% would be fair sinceyou recently joined KBB and you haven't invested any cash in the company. When re financially able, allfour of us will take a salary, in addition to our points.

Also, about your ask for a temporary salary, unfortunately we won't be able to do it. Right now, as it is, westruggle to make payroll every week and we pay the factory staff, later and later, almost every week. On afew occasions, Carol has even advanced payroll out of her own savings. Damani and I have been sufferingit out since he resigned in 2012 and he's still continuing to invest his pension in the business.

-Karen

On Thu, Oct 22, 2015 at 11:22 AM, Jim Thomas <[email protected]> wrote:

II Karen,

;, I need to plan my day. When did you want to do a conference call and who would be on the call? Do we'

really need a call? Why not just email what it is you have to chat about? It might save some time.

Best Regards,




I, Cell # 908-334-2801

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8/3/2017 Gmail - Conferencecall.

Karen Tappin

Beauty Boss


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Jim Thomas <[email protected]> Thu, Oct 22, 2015 at 6:54 PMTo: Karen Tappin <[email protected]>

Cc: Damani Saunderson <[email protected]>, jcsaphina@këërst÷jyte=..:..:: = com

Absolutely. We will see you there.

Let's do Healthy Gardens. It's just across the street. I'llI'I'send address.

Best Regards,




Cell # 908-334-2801

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From: Karen Tappin [mailto:[email protected])Sent: Thursday, October 22, 2015 6:20 PM


Cc: Damani Saunderson <[email protected]>; josephine@karerisbüdybeautifü:.comisuvuyueautifu].


Jim Thomas <j!m@kerensbadybeautifu!.com> Thu, Oct 22, 2015 at 6:55 PMTo: Karen Tappin <[email protected]>Cc: Damani Saunderson <[email protected]>, jn-ephine@ksisrisbadybeautifúLcom1

Do you need me to prepare anything for this meeting?

Best Regards,




Cell # 908-334-2801

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From: Karen Tappin [mailto:[email protected]]Sent: Thursday, October 22, 2015 6:20 PM


Cc: Damani Saunderson <[email protected]>; [email protected]


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IQiren Tappin <[email protected]> Thu, Oct 22, 2015 at 7:13 PMTo: Jim Thomas <[email protected]>

Cc: Damani Saunderson <[email protected]>, [email protected]

You can prepare a list of what is completed, if anything, what's left to be done and the spreadsheets that correspond toeach item.Guated teM hidden]

https://mail.google.corn/mail/u/0/?ui=2&ik=65cb52e5dc&jsver=bbsv5zgiMgE.en.&view=pt&q=jim%20thomas&qs=true&search=query&th=1509 d4tt1877080&si ... 7/7

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v2Affirmation in Support of Motion to Quash-Stay Action