On March 06, 2018 a
Party Notice
was filed
involving a dispute between
Carolyn Disbrow,
and
Brian Strong,
Global Solutions Appliance Repair Inc.,
Global Solutions Appliance Repair Nyc Llc,
Hadas A. Jacobi,
Keri Strong,
Metro Management & Development, Inc.,
The Board Of Managers Of The Normandie Condominium,
The Normandie Condominium,
for Commercial - Contract
in the District Court of New York County.
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7oo Crossroads Building 19oo Main Place Tower
2 State Street, Rochester, New York 14614 Buffalo, New York 142o2
P 585987.2800 F 585.454.3968 P 716.248.3200 F 716.854.5100
ATTORNEYS IVriter's Direct Dia/Niimber: 716.248.3215
lVriter's Direct Fax Niimber 716.248.3315
woodsoviatt.com
Emaih rearboite@moodsoviatt.com
March 6, 2018
FACSIMILE TRANSMITTAL
TO 516-493-3385 AND NYSCEF
Hon. Stephen A. Bucaria, J.S.C.
New York State Supreme Court for Nassau County
100 Supreme Court Drive
Mineola, New York 11501
Re: Scottish American Capital, LLC, et al. v. Arthur Golann, et al.
Index No. 609073/2016
Request for Extension of Deadline to Complete Depositions
Dear Justice Bucaria:
This office represents Scottish American Capital, LLC and Scottish American Insurance General
Agency, Inc., plaintiffs in the above-referenced matter (together, "SAC"). Per Your Honor's instructions
at prior conferences, I write to notify the Court of potential delays in completion of depositions and to
request a modest extension of the deadline to complete depositions on March 15, 2018 set by the Court
pursuant to the Stipulation entered on October 31, 2017 (Doc. No. 75).
With the exception of the deposition of Arthur Golann, all depositions noticed by the parties
were completed last week (a total of 8 depositions). Due to scheduling constraints of witnesses and
counsel, the earliest date that Mr. Golann is available to be deposed is March 29, 2018, two weeks after
the scheduled deadline for completion of depositions. Accordingly, SAC requests that the deadline for
completion of depositions and other discovery be extended until April 30, 2018 to permit SAC an
opportunity to serve supplemental requests, if any, based on Mr. Golann's testimony.
Additionally, the parties have exchanged more than 200,000 pages of documents in this case and,
given the immense scope of paper discovery, the parties have been working in good faith to produce
documents on a rolling basis. In January and February 2018, SAC received supplemental productions of
documents containing more than 7,000 pages of documents. SAC has engaged an expert accounting
firm to prepare an economic damages report which could not be completed without the benefit of
reviewing all documentary evidence of potential damages. SAC hopes to have a report of its damages
expert produced to Defendants this week. SAC also made a supplemental production of documents in
February 2018 containing approximately 50,000 pages of additional documents, most of which were
insurance policies and related information. Given the totality of the foregoing, the extension requested
People-'
The art of representing
{5884957: 1
Hon. Stephen A. Bucaria, J.S.C.
Page 2
March 6, 2018
above will afford the parties an opportunity to complete discovery without unreasonably the
prolonging
conclusion of this case.
Notwithstanding Your Honor's decision on the above request, SAC would like to retain the date
of the scheduled status conference on March 15, 2018. SAC would like to again thank Your Honor for
permitting the undersigned counsel to participate in that status conference by telephone.
Prior to submission to the Court, this correspondence was circulated to counsel for Defendants
who raised no objection to the requests herein.
Respectfully submitted,
WOODS 0 7 ATT GILMAN LLP
Robert C. Carbone
Please direct responses to Buffalo Office
cc: Keith J. Singer, Esq. (via e-mail to ksinger@abramslaw.com)
Alex Leibson, Esq. (via e-mail to aleibson@abramslaw.com)
RCC/rec
people'
{5884987: l The art of representing
Document Filed Date
March 06, 2018
Case Filing Date
March 06, 2018
Category
Commercial - Contract
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7oo Crossroads Building 19oo Main Place Tower 2 State Street, Rochester, New York 14614 Buffalo, New York 142o2 P 585987.2800 F 585.454.3968 P 716.248.3200 F 716.854.5100 ATTORNEYS IVriter's Direct Dia/Niimber: 716.248.3215 lVriter's Direct Fax Niimber 716.248.3315 woodsoviatt.com Emaih rearboite@moodsoviatt.com March 6, 2018 FACSIMILE TRANSMITTAL TO 516-493-3385 AND NYSCEF Hon. Stephen A. Bucaria, J.S.C. New York State Supreme Court for Nassau County 100 Supreme Court Drive Mineola, New York 11501 Re: Scottish American Capital, LLC, et al. v. Arthur Golann, et al. Index No. 609073/2016 Request for Extension of Deadline to Complete Depositions Dear Justice Bucaria: This office represents Scottish American Capital, LLC and Scottish American Insurance General Agency, Inc., plaintiffs in the above-referenced matter (together, "SAC"). Per Your Honor's instructions at prior conferences, I write to notify the Court of potential delays in completion of depositions and to request a modest extension of the deadline to complete depositions on March 15, 2018 set by the Court pursuant to the Stipulation entered on October 31, 2017 (Doc. No. 75). With the exception of the deposition of Arthur Golann, all depositions noticed by the parties were completed last week (a total of 8 depositions). Due to scheduling constraints of witnesses and counsel, the earliest date that Mr. Golann is available to be deposed is March 29, 2018, two weeks after the scheduled deadline for completion of depositions. Accordingly, SAC requests that the deadline for completion of depositions and other discovery be extended until April 30, 2018 to permit SAC an opportunity to serve supplemental requests, if any, based on Mr. Golann's testimony. Additionally, the parties have exchanged more than 200,000 pages of documents in this case and, given the immense scope of paper discovery, the parties have been working in good faith to produce documents on a rolling basis. In January and February 2018, SAC received supplemental productions of documents containing more than 7,000 pages of documents. SAC has engaged an expert accounting firm to prepare an economic damages report which could not be completed without the benefit of reviewing all documentary evidence of potential damages. SAC hopes to have a report of its damages expert produced to Defendants this week. SAC also made a supplemental production of documents in February 2018 containing approximately 50,000 pages of additional documents, most of which were insurance policies and related information. Given the totality of the foregoing, the extension requested People-' The art of representing {5884957: 1 Hon. Stephen A. Bucaria, J.S.C. Page 2 March 6, 2018 above will afford the parties an opportunity to complete discovery without unreasonably the prolonging conclusion of this case. Notwithstanding Your Honor's decision on the above request, SAC would like to retain the date of the scheduled status conference on March 15, 2018. SAC would like to again thank Your Honor for permitting the undersigned counsel to participate in that status conference by telephone. Prior to submission to the Court, this correspondence was circulated to counsel for Defendants who raised no objection to the requests herein. Respectfully submitted, WOODS 0 7 ATT GILMAN LLP Robert C. Carbone Please direct responses to Buffalo Office cc: Keith J. Singer, Esq. (via e-mail to ksinger@abramslaw.com) Alex Leibson, Esq. (via e-mail to aleibson@abramslaw.com) RCC/rec people' {5884987: l The art of representing