Exhibit,Appendix: Richard Von Der Lieth v. Barbara Giordano a/k/a Barbara Leonaggeo a/k/a Barbara Giordano-Leonaggeo, Roger Leonaggeo, Jack Giordano, M-M2 Re Holdings 4, Llc, H&L Equine, Llc, Portfolio Recovery Associates, Llc, Razor Capital Ii, Llc a/p/o Credit One Bank, N.A., Catania, Mahon, Milligram & Rider, Pllc, John Doe 1-10 And Jane Doe 1-10, As Possible Heirs And Distributees Of The Interest Of Jack Giordano, If Deceased, John Doe 1-10, Jane Doe 1-10

• 
• 

						
                                
Preview
                                FILED:         DUTCHESS           COUNTY        CLERK        10/31/2022             07:14        PM                  INDEX    NO.   2021-51452
   NYSCEF     DOC.   NO.   189                                                                                RECEIVED      NYSCEF:     10/31/2022



                                Cara      Whalen
                                RE:    Fwd:        Cara's       email      to   Jordan
                                Oct     6,2417         at   11:52:46         AM
                                Barbara         Giordano-Leonaggeo


                 Barbara

                 Thank    you   for forwarding     the  email. I am deeply       concerned      about   the miscommunications
                 and   accusations     being    thrown.around       by the lenders     and their    assistants    about   this matter.
                 The tone     and   harassment      is unnecessary.

                 A you know,      I have   been   in constant     contact   with  you both and you        fully agreed    to the
                 terms in which      I set forth below     to Jordan.    We even      reconfirmed     these   terms    with  you   again
                 yesterday prior to sending         the email. lt seems       as though     you,   Roger and I are      on the same
                 page.    However, the attorney        for the lender     is letting  his client run   rampant.     There    are'
                 unnecessary       threats being     made.    The   effort  on our   end   has   been from     the beginning     to
                 come    to a resolution     given   the  circumstances.       Clearly   this  has   not  be  communicated
                 clearly  to the lender.     lt is deeply   concerning the position         in which is being      taken   given the
                 defective    title,defective    mortgage      (both  incorrect   description     and the   original   being   lost),
                 defective    agreement,      lack  ol representation,      lack  ol title insurance     and the    issue  with   the
                 home     equity  theft  prevention     act. Nevertheless,       I am awaiting     a response     from   Jordan and
                 will.reach   out to you    today    once I hear    further.

                 This  email    is not to be forwarded       to 3d   parties   and   should   be  kept confidential      between     us.

                 I am available     to discuss    further   as you   would like.

                 Thank you,

                 Cara

                 MACKEY
                 BUTTS         &
                 WISE
                 LLP

                 32OA Franklin      Avenue
                 Millbrook,    New York     12545
                 P: (845) 677 -      6700
                 F: (8a5) 677 -      2202