SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
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PIONEER INITIATIVES, INC., independently, and
PIONEER INITIATIVES, INC., derivatively on behalf
of all creditors ofFLG Lacrosse, Inc.,
Plaintiffs,
- against -
fl$ LACROSSE, INC. a/k/a FOR THE LOVE OF
THE GAME and GREG MICHAEL WINK.OFF,
individually,
Defendants.
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SUMMONS
TO THE ABOVE-NAMED DEFENDANTS:
Index No.
Plaintiff Designate Nassau
County as the place of trial.
The basis of venue is the
Residence of Plaintiff Pioneer
Initiatives, Inc.
YOU ARE SUMMONED to answer the Complaint in this action and to serve a copy of
your answer, or, if the Complaint is not served with this Summons, to serve a Notice of
Appearance, on the plaintiff's attorneys within twenty (20) days after the service of this
Summons, exclusive of the day of service (or within thirty (30) days after service is complete if
this Summons is not personally delivered to you within the State of New York); and in case of
your failure to appear or answer, judgment will be taken against you by default for the relief
demanded in the Complaint.
Dated: May 8, 2018
W antagh, New York
To: Michael Winkoff, President
fl$ Lacrosse, Inc.
345 Main Street, Unit #8
Huntington, NY 11743
Michael Winkoff, Individually
47 Crescent Beach Drive
Huntington, NY 11743

VERIFIED COMPLAINT
PIONEER INITIATIVES, INC., independently, and Pioneer Initiatives, Inc., derivatively
on behalf of all creditors of fl$ Lacrosse, Inc. (the "Plaintiff') by and through its undersigned
counsel, LaMonica Herbst & Maniscalco, LLP, as and for its verified complaint (the
"Complaint") against defendants fl$ LACROSSE, INC. a/k/a FOR THE LOVE OF THE
GAME ("fl$ Lacrosse") and GREG MICHAEL WINKOFF, individually ("Winkoff')
( collectively, fl$ Lacrosse and Winkoff shall be referred to as "Defendants"), alleges as
follows:
Preliminary Statement
I. Plaintiffs bring these claims independently and derivatively on behalf of all
creditors of defendant fl$ Lacrosse for, among other things, breach of contract, fraudulent
inducement and breach of fiduciary duty. As more fully set forth herein, there can be no doubt
that the individual defendant Greg Michael Winkoff has engaged, and continues to engage, in a
fraud on the Plaintiffs and the creditors of the defendant fl$ Lacrosse. Through his manipulation, misrepresentation and fraudulent inducement, he caused a buyout of the defendant
fl$ Lacrosse and has been using the cash flow and revenue of the company for his own
personal purposes and diverting it to third parties for his benefit. In doing so, he has purposely
defaulted on a Consulting Agreement only four (4) months after execution despite having the
financial ability to pay it, and has threatened to place the company into bankruptcy or simply
shut it down. Not only does this jeopardize the continued viability of the defendant fl$
Lacrosse, but also the hundreds of players who participate in its programs and the various
contracts for tournaments over the next several years. His actions and behavior are inconsistent
with sound logical principles and reasonable business judgment. At the very least, he should be
removed from his position and this Court should consider the immediate appointment of a
receiver who will act in the best interest of the company, the players, and all of its creditors. But
for judicial intervention, the individual defendant Greg Michael Winkoff is likely to continue
diverting corporate assets for his personal benefit and that of his family to the detriment of
defendant fl$ Lacrosse and its creditors.
THE PARTIES
2. Plaintiff Pioneer Initiatives, Inc. is a New York corporation with a principal place
of business at 1400 Old Country Road, Westbury, New York 11590.
3. Defendant fl$ Lacrosse is a New York corporation with a principal place of
business at 345 Main Street, Unit #8, Huntington, New York 11743.
4. Defendant Greg Michael Winkoff is an individual citizen of the United States
with a personal residence at 4 7 Crescent Beach Drive, Huntington, New York 117 43.