On February 24, 2021 a
Exhibit,Appendix
was filed
involving a dispute between
Miguel Angel Abreu Hernandez,
and
345 East 26 Llc,
Lg Construction Management Inc.,
for Torts - Other (Labor Law)
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 02/24/2022 09:56 AM INDEX NO. 504475/2021
NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 02/24/2022
From: Giulia Escobar
"kkelly@defensecounsel.com"
To:
Cc: Ana E. Colon
Subject: RE: RE: 504475/2021MIGUEL ANGEL ABREU HERiiAiifJtZ
v. 345 EAST 26 LLC et al
Date: Tuesday, January 25, 2022 4:15:53
PM
Attachments: imaae001.ipa
Good Afternoon,
As discussed by our recent phone call,Plaintiff has attempted in good faith to obtain discovery
responses to Plaintiff'sdemands to Defendant LG CONSTRUCTION MANAGEMENT INC dated August
2021- for a Verified Billof Particulars as to Affirmative Combined Demands and Notice
9, Defenses,
for Discovery and Inspection.
To date, Plaintiffhas not received responses to Plaintiff'sdemands.
As a result, Plaintiffwillseek judicial intervention to compel Defendant's discovery responses via
motion.
Ifyou have any questions, do not hesitate to reach out.
Best Regards,
Giulia P. Escobar, Esq.
WILLIAM SCHWITZER & ASSOCIATES, P.C.
10th
820 Second Avenue, Floor
New York, New York 10017
O: 212-683-3800 x223
F: 212-685-9405
gescobar@wsatlaw.com
This electronic message transmission contains information from the law firm of William Schwitzer
& Associates PC, which may be confidential or privileged. The information is intended to be for the
use of the individual or entity named above. If you are not the intended recipient, be aware thatany
disclosure, copying, distribution, or use of the contents of this information isprohibited. If you have
received this electronic transmission in error, please delete the message and notify us by telephone
(212) 683-3800 immediately.
dPlease consider the environment before printingthise-mail
From: Ana E. Colon
Sent: Wednesday, January 5, 2022 10:51 AM
'kkelly@defensecounsel.com'
To:
Cc: Ivanna Tellez
Subject: RE: 504475/2021 MIGUEL ANGEL ABREU HERNANDEZ v. 345 EAST 26 LLC et al
Dear Counselor:
FILED: KINGS COUNTY CLERK 02/24/2022 09:56 AM INDEX NO. 504475/2021
NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 02/24/2022
Attached please find our previous correspondence regarding the above subject matter. Please be
advised that this is a final good faith attempt to obtain the outstanding discovery responses and
schedule depositions of all parties.
Should you not provide responses by January 12, 2022, we shall file an immediate motion.
Please be guided accordingly. Thank you
Ana E. Colón, Litigation Paralegal
WILLIAM SCHWITZER & ASSOCIATES, P.C.
820 Second Avenue
New York, New York 10017
Tel: 212-683-3800 Ext. 314
Fax: 212-685-2356
Email: AColon@wsatlaw.com
Website: www.wsatlaw.com
Preview
FILED: KINGS COUNTY CLERK 02/24/2022 09:56 AM INDEX NO. 504475/2021 NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 02/24/2022 From: Giulia Escobar "kkelly@defensecounsel.com" To: Cc: Ana E. Colon Subject: RE: RE: 504475/2021MIGUEL ANGEL ABREU HERiiAiifJtZ v. 345 EAST 26 LLC et al Date: Tuesday, January 25, 2022 4:15:53 PM Attachments: imaae001.ipa Good Afternoon, As discussed by our recent phone call,Plaintiff has attempted in good faith to obtain discovery responses to Plaintiff'sdemands to Defendant LG CONSTRUCTION MANAGEMENT INC dated August 2021- for a Verified Billof Particulars as to Affirmative Combined Demands and Notice 9, Defenses, for Discovery and Inspection. To date, Plaintiffhas not received responses to Plaintiff'sdemands. As a result, Plaintiffwillseek judicial intervention to compel Defendant's discovery responses via motion. Ifyou have any questions, do not hesitate to reach out. Best Regards, Giulia P. Escobar, Esq. WILLIAM SCHWITZER & ASSOCIATES, P.C. 10th 820 Second Avenue, Floor New York, New York 10017 O: 212-683-3800 x223 F: 212-685-9405 gescobar@wsatlaw.com This electronic message transmission contains information from the law firm of William Schwitzer & Associates PC, which may be confidential or privileged. The information is intended to be for the use of the individual or entity named above. If you are not the intended recipient, be aware thatany disclosure, copying, distribution, or use of the contents of this information isprohibited. If you have received this electronic transmission in error, please delete the message and notify us by telephone (212) 683-3800 immediately. dPlease consider the environment before printingthise-mail From: Ana E. Colon Sent: Wednesday, January 5, 2022 10:51 AM 'kkelly@defensecounsel.com' To: Cc: Ivanna Tellez Subject: RE: 504475/2021 MIGUEL ANGEL ABREU HERNANDEZ v. 345 EAST 26 LLC et al Dear Counselor: FILED: KINGS COUNTY CLERK 02/24/2022 09:56 AM INDEX NO. 504475/2021 NYSCEF DOC. NO. 33 RECEIVED NYSCEF: 02/24/2022 Attached please find our previous correspondence regarding the above subject matter. Please be advised that this is a final good faith attempt to obtain the outstanding discovery responses and schedule depositions of all parties. Should you not provide responses by January 12, 2022, we shall file an immediate motion. Please be guided accordingly. Thank you Ana E. Colón, Litigation Paralegal WILLIAM SCHWITZER & ASSOCIATES, P.C. 820 Second Avenue New York, New York 10017 Tel: 212-683-3800 Ext. 314 Fax: 212-685-2356 Email: AColon@wsatlaw.com Website: www.wsatlaw.com