Preview
FILED: KINGS COUNTY CLERK 02/22/2021 04:47 PM INDEX NO. 508009/2013
NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 02/22/2021
EXHIBIT I
FILED: KINGS COUNTY CLERK 02/22/2021 04:47 PM INDEX NO. 508009/2013
NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 02/22/2021
Ginette Portera
From: levinengrossman@aol.com
Sent: Friday, December 6, 2019 3:26 PM
To: Jennifer Piazza; Pat@lawahl.com; mbatti@schiavetti.com; sgarry@csgilplaw.com
Cc: Ginette Portera
Subject: Re: Grayton v Bhayani - EBT of Dr Bhayani
I am sorry we are going to have to adj.Dr. ebt Monday my attyhas togo to Queens to plck a jury.
Thanks Laura
---Original Message-
From: Jennifer Piazza
To: levinengressman@aol.com ; Pat@lawahl.com ;
mbottl@schiavetti.com ; agarry@ce!!p!ew.com
Cc: Glnette Portera
Sent: Fri,Dec 6, 2019 2:24 pm
Subject: RE: Grayton v Bhayani- EBT of Dr Bhayani
Just so I don't forget later, ifthis does go forward, it should be a 12 pm start. Thanks!
Jennifer M. Piazza
Office Manager
Brown, Gaujean, Kraus & Sastow, PLLC
- 10th Floor
One Building
1 North • White NY 10601
Broadway Plains,
914.949.5300 = 914.949.6284
(T) (F)
iniazza@bakslaw.com
www.bakslaw.com
Attorneys at Law
BROWN -
GAUJEAN
-
KRAUS SASTOW, PLLC
PRIVILEGED AND CONFIDENTIAL
ATTORNEY CLIENT COMMUNICATION
NOTICE: may contain
This cornmunication or other ccñfidêñtiâi
privileged information to be for the use of the individual(s)
intended narned above. If you
are not the intended or believe
recipient, that you have
receivedthis communication
in error,
please do not print, copy, disseminate
retransmit, or
otherwiseuse this Mfer=et!on.
Please to the sender
Indicate that you have received error and delete the copy that you have
this emailin
received.Thank you
From: levinengrossman@aol.com <|éviñeñgrossmâñ@âol.com>
Sent: Friday, December 6, 2019 2:03 PM
To: Jennifer Piazza ; Pat@Iawahl.com; mbéü| s-|davetti.com; agarry@csgilplaw.com
Cc: Ginette Portera
Subject: Re: Grayton v Bhayani - EBT of Dr Bhayani
I am sorry but rightnow I am waiting to see if acase isgoing to settlefor Monday if it doesn't
the atty on thiscase willbe
forced to
go to Queens to pick a jury.I wilt
keep you informed. Thanks Laura
1
FILED: KINGS COUNTY CLERK 02/22/2021 04:47 PM INDEX NO. 508009/2013
NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 02/22/2021
--Original Message-
From: Jennifer Piazza
To: Patricia Rowbottom ; lev|ñériqrossman@aol.com ;
mbotti@schiavetti.com ; sqarry ge;ijjplaw.com
Cc: Ginette Portera
Sent: Fri,Dec 6, 2019 1:22 pm
Subject: RE: Grayton v Bhayani - EBT of Dr Bhayani
Hi all - do we have a location yet for Monday? I need to let our client know
Jennifer M. Piazza
Office Manager
Brown, Gaujean, Kraus & Sastow, PLLC
• 10th
One Building Floor
1 North - White NY 10601
Broadway Plains,
914.949.5300 • 914.949.6284
(T) (F)
jpiazza(dtbqkslaw.com
www.bqkslaw.com
Attorneys at Law
BROWN •
GAUJEAN
-
KRAUS SASTOW, PLLC
PRIVILEGED AND CONFIDENTIAL
ATTORNEY CLIENT COMMUNICATION
NOTICE: This cGirri.,|sat|ón may contain
privileged
or other confidential to be for the use of the ind|vidua|(s)
!‡=n--=±!=ñ intended named above. If you
are not the intended or believe
recipient, that you havereceived
this communication
in error, please
do not print, copy, d|sser
ratrammit, |r ate or
otherwiseuse this inf-'M Please indicate
to the sender
that you have received
this email
in error and delete the copy that you have
received.Thank you
From: Patricia Rowbottom
Sent: Thursday, December 5, 2019 3:06 PM
To: jev_inengrossman@aol.com; Jennifer Piazza ; mbotti@schiavetti.com; sqarry@csallplaw.com
Cc: Ginette Portera
Subject: RE: Grayton v Bhayani - EBT of Dr Bhayani
okay
Patricia Rowbottom
Arshack, Hajek & Lehrman, PLLC
1790 Broadway, Suite 710
New York, New York 10019
Ph - 212-582-6500
Fax - 212-459-0568
Email - pat@[awahl.com
From: levinengrossman@aol.com
Sent: Thursday, December 5, 2019 3:05 PM
To: jplazza@bakslaw.com: Patricia Rowbottom ; mbetti schiavetti.corn;sqarrv@csqllplaw.com
Cc: qportera@bqkslaw.com
Subject: Re: Grayton v Bhayani - EBT of Dr Bhayani
I will
be incontact with you tomorrow
----Original Message-----
From: Jennifer Piazza
2
FILED: KINGS COUNTY CLERK 02/22/2021 04:47 PM INDEX NO. 508009/2013
NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 02/22/2021
To: Patricia Rowbottom ; Melie Botti ; Steven Garry
Cc: |6viñ6ñqrossman@aol.com ; Ginette Portera
Sent: Thu, Dec 5,2019 1:44 pm
Subject: RE: Grayton v Bhayani -EBT ofDr Bhayani
If the plaintiff could reserve a court reporting office in Kings County, that would be
great. Thanks!
Jennifer M. Piazza
Office Manager
Brown, Gaujean, Kraus & Sastow, PLLC
- 10th
One Building FlOO
1 North a White NY 10601
Broadway Plains,
914.949.5300 - 914.949.6284
(T) (F)
lpiazza@bqkslaw.com
www.bqkslaw.cOm
Attorneys at Law
BROWN •
GAUJEAN
=
KRAUS SASTOW, PLLC
PRIVILEGED AND CONFIDENTIAL
ATTORNEY CLIENT COMMUNICATION
NOTICE: This ··é:: .....
Et!z may containprivi|cged information
or other esñdéntia! to be for the use of the indMdë!(s)
intended named above. If you
are not the intended or believe
recipient, this cem-iwinn
that you have received in error,
please do not print, copy, disseminate
retransmit, or
use this iiifüñ
athereel:c aticii.
Please indicate that you have received
to the sender this emall in error and delete the copy that you have
received.Thank you
From: Patricia Rowbottom
Sent: Thursday, December 5, 2019 1:42 PM
To: Jennifer Piazza <|piazza@bgkulevv.com>; Melie Botti ; Steven Garry
Cc: leviriengressman@aol.com; Ginette Portera
Subject: RE: Grayton v Bhayani - EBT of Dr Bhayani
please let me know the location for December 9
Patricia Rowbottom
Arshack, Hajek & Lehrman, PLLC
1790 Broadway, Suite 710
New York, New York 10019
Ph - 212-582-6500
Fax - 212-459-0568
Email - pat@lawahl.com
. . . .
From: Jennifer Piazza
Sent: Friday, Novernber 15, 2019 12:27 PM
To: Melie Botti ; Patricia Rowbottom ; Steven Garry
Cc: levinengrossrñan aol com; Ginette Portera
Subject: RE: Grayton v Bhayani - EBT of Dr Bhayani
I think itwill probably be at a court reporting office in Brooklyn.
3
FILED: KINGS COUNTY CLERK 02/22/2021 04:47 PM INDEX NO. 508009/2013
NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 02/22/2021
Jennifer M. Piazza
Office Manager
Brown, Gaujean, Kraus & Sastow, PLLC
- 10th
One Building FlOOr
1 North - White NY 10601
Broadway Plains,
914.949.5300 - 914.949.6284
(T) (F)
ipiazza@bgkslaw.corn
www.baksiaw.com
Attorneys at Law
BROWN a
GAUJEAN
-
KRAUS SASTOW, PLLC
PRIVILEGED AND CONFIDENTIAL
ATTORNEY CLIENT COMMUNICATION
NOTICE: This communicationmay containprivileged
or other information
confidential intended
to be for the use of the individual(s)
named above.If you
are not the intended or believe
reciplent, that you have received
this con müñ!Gt!en
in error,
please do not print, copy, d!esem!nete
:::::::r.-.|t, or
otherwiseuse this information.
Please indicate
to the sender
that you have received
this email in error and delete the copy that you have
received.Thank you
From: Melie Botti
Sent: Friday, November 15, 2019 12:24 PM
To: Jennifer Piazza ; PatriciaRowbottom ; Steven Garry
Cc: levinengrossman@aol.com; Ginette Portera
Subject: RE: Grayton v Bhayani - EBT of Dr Bhayani
Jennifer - What's the location?
From: Jennifer Piazza
Sent: Friday, November 15, 2019 11:52 AM
To: Melie Botti ; Patricia Rowbottom ; Steven Garry
Cc: levinengrossman@aol.com; Ginette Portera
Subject: RE: Grayton v Bhayani - EBT of Dr Bhayani
It looks like December 9 at 12 pm is good for everyone, please confirm. Thanks!
Jennifer M. Piazza
Office Manager
Brown, Gaujean, Kraus & Sastow, PLLC
- 10th
One Building Floor
1 North - White NY 10601
Broadway Plains,
914.949,5300 - 914.949.6284
(T) (F)
jpiazza@bqkslaw.com
www.b kslaw.com
Attorneys at Law
BROWN -
GAUJEAN
KRAUS •
SASTOW, PLLC
FILED: KINGS COUNTY CLERK 02/22/2021 04:47 PM INDEX NO. 508009/2013
NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 02/22/2021
PRIVILEGED AND CONFIDENTIAL
ATTORNEY CL1ENT COMMUNICATION
NOTICE: This cammür,|cation
may containprMIeged or other confidential
|ñfGrmät|Gn intended
to be for the use of the|r.d|v|dsa|(a)
narned above.If you
are not the intended or belfeve that you have
recipient, received this cGmmüñicätian please
in error, do not print, copy, diccc.T.|nate or
retransmit,
otherwiseuse this information.
Please indicate
to the sender that you have received
this email ln error and delete the copy that you have
received.Thank you
From: Melie Botti
Sent: Friday, November 15, 2019 11:47 AM
To: Jennifer Piazza ; Patricia Rowbottom ; Steven Garry
Cc: levinengrossman@aol.com; Ginette Portera
Subject: RE: Grayton v Bhayani - EBT of Dr Bhayani
Hi Jenifer and everyone else- I spoke it's to get another - Can we Dec 9th -Than 11th I am not
partner, okay attorney able
to do fullcalendar. Please letme know -Thank youl
From: Jennifer Piazza
Sent: Friday, November 15, 2019 11:37 AM
To: PatriciaRowbottom ; Steven Garry ; Melie Botti
Cc: levinenqrossman@aol.com; Ginette Portera
Subject: RE: Grayton v Bhayani - EBT of Dr Bhayani
Not yet, I waS hoping Melie could see if someone in her office could do one of the
other available dates that everyone else could do.
Jennifer M. Piazza
Office Manager
Brown, Gaujean, Kraus & Sastow, PLLC
• 10th
One Building plOOr
1 North - White NY 10601
Broadway Plains,
914.949.5300 - 914.949.6284
(T) (F)
jpiazza@bqkslaw.com
www. kslaw.com
Attorneys at Law
BROWN -
GAUJEAN
-
KRAUS SASTOW, PLLC
PRIVILEGED AND CONFIDENTIAL
ATTORNEY CLIENT COMMUNICATION
NOTICE: This communicationmay containprivileged
or other corifideñtiâ| to be for the use of the !nd!vidue!(s)
infGrmst|Gn intended narned above. If you
are not the intended
recipient, that you have received
or believe this ceiiiiiiüiiicätion
in error,
please do not print, copy,
r*¤n9m!t disseminateor
otherwiseuse this information.
Please indicate
to the sender
that you have received in error and delete
this email the copy that you have
received.Thank you
From: PatriciaRowbottom
Sent: Thursday, November 14, 2019 3:09 PM
To: Jennifer Plazza ; Steven Garry ; Melie Botti
Cc: levinenqrossman@aol.com; Ginette Portera
Subject: RE: Grayton v Bhayani - EBT of Dr Bhayani
Did anything ever get scheduled ?
5
FILED: KINGS COUNTY CLERK 02/22/2021 04:47 PM INDEX NO. 508009/2013
NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 02/22/2021
PatriciaRowbottom
Arshack, Hajek & Lehrman, PLLC
1790 Broadway, Suite 710
New York, New York 10019
Ph - 212-582-6500
Fax - 212-459-0568
Email - pat@Iawahl.com
From: Jennifer Plazza
Sent: Tuesday, November 12, 2019 1:34 PM
To: PatriciaRowbottom ; Steven Garry ; Melie Botti
Cc: levinenqrossman@aol.com; GInette Portera
Subject: RE: Grayton v Bhayani - EBT of Dr Bhayani
Melie, would you be able to see if maybe someone else in your office can be available
on one of the other dates?
Jennifer M. Plazza
Office Manager
Brown, Gaujean, Kraus & Sastow, PLLC
- 10th
One Building FlOOT
1 North = White NY 10601
Broadway Plains,
914.949.5300 - 914.949.6284
(T) (F)
piazza@bqkslaw.com
www-b kslaw.com
Attorneys at Law
BROWN •
GAUJEAN
KRAUS *
SASTOW PLLC
PRIVILEGED AND cONFIDENTIAL
ATTORNEY CUENT COMMUNICATION
NOTICE: This communicationmay contain or other confidential
privileged information to be for the use of the |n±:!dus!(s)
intended named above, If you
are not the intended or believe that you have received
recipient, this commurilcation do not print, copy,
In error, please disseminate
retransmIt, or
otherwiseuse this information.
Please Indicate to the sender
that you have received
this email in error and delete
the copy that you have
received.Thank you
From: Patricia Rowbottom
Sent: Tuesday, November 12, 2019 1:17 PM
To: Steven Garry ; Melie Bottl; Jennifer Plazza
<|plazza@bgkslaw.com>
Cc: levinengrossman@aol.com; Ginette Portera
Subject: RE: Grayton v Bhayani - EBT of Dr Bhayani
We can do December 9 or 11th
PatriciaRowbottom
Arshack, Hajek & Lehrman, PLLC
1790 Broadway, Suite 710
New York, New York 10019
Ph - 212-582-6500
Fax - 212-459-0568
Email - pat@lawahl.com
6
FILED: KINGS COUNTY CLERK 02/22/2021 04:47 PM INDEX NO. 508009/2013
NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 02/22/2021
From: Steven Garry
Sent: Tuesday, November 12, 2019 9:59AM
To: Melie Botti ; Jennifer Piazza
Cc: ley|ñeñqrossrñañ@aol.com; Patricia Rowbottom ; Ginette Portera
Subject: RE: Grayton v Bhayani -EBT of Dr Bhayani
I can do the 9th OF th. Bear In mind I believewe have another conference on 16th
4th, the
Steven E. Garry
Partner
Costello, Shea & Gaffney LLP
100 Merrick Road East BIdg, Suite 218
Rockville Centre, New York 11570
Tel (212) 413-8902
Fax (516) 764-9104
sqarrv@csqllplaw.com
From: Melie Bottifmailto:mbotti@schiavetti.com]
Sent: Tuesday, November 12, 2019 9:53 AM
To: Jennifer Piazza
Cc: levinenqressrrianGaul.com; Steven Garry ; pat@lawahl.com; Ginette Portera
Subject: RE: Grayton v Bhayani - EBT of Dr Bhayani
Good Jennifer - The date that m attorney isavailab|e will be December 18th
morning only -Sorry
From: Jennifer Piazza
Sent: Monday, November 11, 2019 2:59 PM
To: Melie Botti
Cc: levinengrossman@aol.com; sqarrv@csqllplaw.com; pat@iewahl.com; Ginette Portera
Subject: RE: Grayton v Bhayani - EBT of Dr Bhayani
Good afternoon. Please Consider the following dateS for the deposition of Dr. Bhayani:
December 4, 9, 11, 18. We would need to start at 12 pm. Thank you.
Jennifer M. Piazza
Office Manager
Brown, Gaujean, Kraus & Sastow, PLLC
- 10th
One Building Floor
1 North - White NY 10601
Broadway Plains,
914.949.5300 - 914.949.6284
(T) (F)
jpiazza@bqkslaw.com
www. ksiaw.com
Attorneys at Law
BROWN -
GAUJEAN
-
KRAUS SASTOW, PLLC
PRIVILEGED AND CONFIDENTIAL
ATTORNEY CLIENT COMMUNICATION
7
FILED: KINGS COUNTY CLERK 02/22/2021 04:47 PM INDEX NO. 508009/2013
NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 02/22/2021
NOTICE: This ccmmüñ!cat!cñ privileged
or other conf! "
may contain nt!e! information
Intended
to be for the use of the ! ) named above.If you
are not the intended
recipient, that you have
or believe received
this e ::=ianon please
In error, do not print, copy, disseminate
retransmit, or
oth6rw|56use this !nfermet!en.
Please indicate that you have received
to the sender this email In error and delete
the copy that you have
received.Thank you
. . .
From: Melie Botti
Sent: Friday, October 25, 2019 12:41 PM
To: Jennifer Piazza
Cc: leviñangrossman@aol.com; sqarry@csq|lcFaw.com; pat@imv_ajn.cp.m; Ginette Portera
Subject: Re: Grayton v Bhayani - EBT of Dr Bhayani
Will get back to you need to see if theattorney can take the date
Sent from my iPhone
On Oct 25, 2019, at 12:11 PM, Jennifer Piazza wrote:
Hi all. How about November 22 as a new date for Dr. Bhayani?
Jennifer M. Piazza
Office Manager
Brown, Gaujean, Kraus & Sastow, PLLC
• 10th
One Building plOOr
1 North • White NY 10601
Broadway Plains,
914.949.5300 • 914.949.6284
(T) (F)
jpiazza( bakslaw.com
www.bqkslaw.com
PRIVILEGED AND CONFIDENTIAL
ATTORNEY CLIENT COMMUNICATION
NOTICE: This communicationmay contain or other confident|al
privileged Intended
Information to be for the use of the individual(s)
named above. If you are not the intended or believe that you have received
recipient, this comrnunication
in error, please do not
print, copy. diesem!nete
retransmit, or otherwise
use this information.
Please Indicate to the sender
that you have received
this
email the copy that you have received.
in error and delete Thank you
From: levinengrossman@aol.com
Sent: Tuesday, October 22, 2019 10:05 AM
To: Jennifer Piazza ; sqarry@csqliplaw.com; oat@lawahl.com;
mbotti@schiavetti.com
Cc: Ginette Portera
Subject: Re: Grayton v Bhayani -EBT of Dr Bhayani
Good Morning,
Sorry but I have to bustthe ebt my atty has a personnel matter that came up and he is not available
tomorrow.
Thanks Laura
---Original Message--
From: Jennifer Piazza
To: levinenqrossman@aol.com ; soarrv@csailplaw.com
; oat |awahl.com ; Melie Botti
Cc: Ginette Portera
Sent: Tue, Oct 22, 2019 9:30 am
Subject: RE: Grayton v Bhayani- EBT of Dr Bhayani
Good morning all. We are prepared to go forward with Dr. Bhayani's
deposition tomorrow. If everyone agrees, maybe we can do this at a court
8
FILED: KINGS COUNTY CLERK 02/22/2021 04:47 PM INDEX NO. 508009/2013
NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 02/22/2021
reporting agency in Brooklyn near the courthouse? We can start at 10:30
AM. Let me know, thanks!
Jennifer M. Plazza
Office Manager
Brown, Gaujean, Kraus & Sastow, PLLC
- 10th
One Building Floor
1 North - White NY 10601
Broadway Plains,
914.949.5300 - 914.949.6284
(T) (F)
jpiazza bgkslaw.com
www.bakslaw.com
PRIVILEGED AND CONFIDENTIAL
ATTORNEY CLIENT COMMUNICATION
NOTICE: This communication
may contain privileged infnrmanan
or other confidential intendedto be for the use of the individual(s)
named above. If you are not the intended or belIeve
recipient, that you have received
this communication
In error,
please do not
print, copy, disseminate
retransmit, or ctrierwise
use this Information.
Please to the sender that you have receIved this
indicate
emailin error and delete
the copy that you have
received.Thankyou
From: Jennifer Piazza
Sent: Friday, Septernber 27, 2019 10:48 AM
To: levinenqrossman@aol.com; sqarry@csq[lplaw.com; pat@lawahi.com; Melie Botti
Cc: Ginette Portera
Subject: Grayton v Bhayani - EBT of Dr Bhayani
Good morning everyone. Arshack's office was not available on 10/16. Can
we please schedule Dr. Bhayani for 10/23? Thank you.
Jennifer M. Piazza
Office Manager
Brown, Gaujean, Kraus & Sastow, PLLC
- 10th
One Building FlOOr
1 North - White NY 10601
Broadway Plains,
914.949.5300 - 914.949.6284
(T) (F)
jpiazza@bqkslaw.com
www.bgkslaw.com
PRIVILEGED AND CONFIDENTIAL
ATTORNEY CLIENT COMMUNICATION
NOTICE: ThIs coi may contain
ication or other confidential
privileged !:± f!e-:
intendedto be for the use of the !nd!v!due!(s)
named above, If you are not the Intended or be[Ieve that you have received
recipient, this comme:icet!on
In error, please do not
print, copy, disseminate
retransmit, or otherwise
use this information.
Please indicate
to the sender
that you have received
this
emailin error and delete the copy that you have received.
Thankyou
9
Preview
FILED: KINGS COUNTY CLERK 02/22/2021 04:47 PM INDEX NO. 508009/2013 NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 02/22/2021 EXHIBIT I FILED: KINGS COUNTY CLERK 02/22/2021 04:47 PM INDEX NO. 508009/2013 NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 02/22/2021 Ginette Portera From: levinengrossman@aol.com Sent: Friday, December 6, 2019 3:26 PM To: Jennifer Piazza; Pat@lawahl.com; mbatti@schiavetti.com; sgarry@csgilplaw.com Cc: Ginette Portera Subject: Re: Grayton v Bhayani - EBT of Dr Bhayani I am sorry we are going to have to adj.Dr. ebt Monday my attyhas togo to Queens to plck a jury. Thanks Laura ---Original Message- From: Jennifer Piazza To: levinengressman@aol.com ; Pat@lawahl.com ; mbottl@schiavetti.com ; agarry@ce!!p!ew.com Cc: Glnette Portera Sent: Fri,Dec 6, 2019 2:24 pm Subject: RE: Grayton v Bhayani- EBT of Dr Bhayani Just so I don't forget later, ifthis does go forward, it should be a 12 pm start. Thanks! Jennifer M. Piazza Office Manager Brown, Gaujean, Kraus & Sastow, PLLC - 10th Floor One Building 1 North • White NY 10601 Broadway Plains, 914.949.5300 = 914.949.6284 (T) (F) iniazza@bakslaw.com www.bakslaw.com Attorneys at Law BROWN - GAUJEAN - KRAUS SASTOW, PLLC PRIVILEGED AND CONFIDENTIAL ATTORNEY CLIENT COMMUNICATION NOTICE: may contain This cornmunication or other ccñfidêñtiâi privileged information to be for the use of the individual(s) intended narned above. If you are not the intended or believe recipient, that you have receivedthis communication in error, please do not print, copy, disseminate retransmit, or otherwiseuse this Mfer=et!on. Please to the sender Indicate that you have received error and delete the copy that you have this emailin received.Thank you From: levinengrossman@aol.com <|éviñeñgrossmâñ@âol.com> Sent: Friday, December 6, 2019 2:03 PM To: Jennifer Piazza ; Pat@Iawahl.com; mbéü| s-|davetti.com; agarry@csgilplaw.com Cc: Ginette Portera Subject: Re: Grayton v Bhayani - EBT of Dr Bhayani I am sorry but rightnow I am waiting to see if acase isgoing to settlefor Monday if it doesn't the atty on thiscase willbe forced to go to Queens to pick a jury.I wilt keep you informed. Thanks Laura 1 FILED: KINGS COUNTY CLERK 02/22/2021 04:47 PM INDEX NO. 508009/2013 NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 02/22/2021 --Original Message- From: Jennifer Piazza To: Patricia Rowbottom ; lev|ñériqrossman@aol.com ; mbotti@schiavetti.com ; sqarry ge;ijjplaw.com Cc: Ginette Portera Sent: Fri,Dec 6, 2019 1:22 pm Subject: RE: Grayton v Bhayani - EBT of Dr Bhayani Hi all - do we have a location yet for Monday? I need to let our client know Jennifer M. Piazza Office Manager Brown, Gaujean, Kraus & Sastow, PLLC • 10th One Building Floor 1 North - White NY 10601 Broadway Plains, 914.949.5300 • 914.949.6284 (T) (F) jpiazza(dtbqkslaw.com www.bqkslaw.com Attorneys at Law BROWN • GAUJEAN - KRAUS SASTOW, PLLC PRIVILEGED AND CONFIDENTIAL ATTORNEY CLIENT COMMUNICATION NOTICE: This cGirri.,|sat|ón may contain privileged or other confidential to be for the use of the ind|vidua|(s) !‡=n--=±!=ñ intended named above. If you are not the intended or believe recipient, that you havereceived this communication in error, please do not print, copy, d|sser ratrammit, |r ate or otherwiseuse this inf-'M Please indicate to the sender that you have received this email in error and delete the copy that you have received.Thank you From: Patricia Rowbottom Sent: Thursday, December 5, 2019 3:06 PM To: jev_inengrossman@aol.com; Jennifer Piazza ; mbotti@schiavetti.com; sqarry@csallplaw.com Cc: Ginette Portera Subject: RE: Grayton v Bhayani - EBT of Dr Bhayani okay Patricia Rowbottom Arshack, Hajek & Lehrman, PLLC 1790 Broadway, Suite 710 New York, New York 10019 Ph - 212-582-6500 Fax - 212-459-0568 Email - pat@[awahl.com From: levinengrossman@aol.com Sent: Thursday, December 5, 2019 3:05 PM To: jplazza@bakslaw.com: Patricia Rowbottom ; mbetti schiavetti.corn;sqarrv@csqllplaw.com Cc: qportera@bqkslaw.com Subject: Re: Grayton v Bhayani - EBT of Dr Bhayani I will be incontact with you tomorrow ----Original Message----- From: Jennifer Piazza 2 FILED: KINGS COUNTY CLERK 02/22/2021 04:47 PM INDEX NO. 508009/2013 NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 02/22/2021 To: Patricia Rowbottom ; Melie Botti ; Steven Garry Cc: |6viñ6ñqrossman@aol.com ; Ginette Portera Sent: Thu, Dec 5,2019 1:44 pm Subject: RE: Grayton v Bhayani -EBT ofDr Bhayani If the plaintiff could reserve a court reporting office in Kings County, that would be great. Thanks! Jennifer M. Piazza Office Manager Brown, Gaujean, Kraus & Sastow, PLLC - 10th One Building FlOO 1 North a White NY 10601 Broadway Plains, 914.949.5300 - 914.949.6284 (T) (F) lpiazza@bqkslaw.com www.bqkslaw.cOm Attorneys at Law BROWN • GAUJEAN = KRAUS SASTOW, PLLC PRIVILEGED AND CONFIDENTIAL ATTORNEY CLIENT COMMUNICATION NOTICE: This ··é:: ..... Et!z may containprivi|cged information or other esñdéntia! to be for the use of the indMdë!(s) intended named above. If you are not the intended or believe recipient, this cem-iwinn that you have received in error, please do not print, copy, disseminate retransmit, or use this iiifüñ athereel:c aticii. Please indicate that you have received to the sender this emall in error and delete the copy that you have received.Thank you From: Patricia Rowbottom Sent: Thursday, December 5, 2019 1:42 PM To: Jennifer Piazza <|piazza@bgkulevv.com>; Melie Botti ; Steven Garry Cc: leviriengressman@aol.com; Ginette Portera Subject: RE: Grayton v Bhayani - EBT of Dr Bhayani please let me know the location for December 9 Patricia Rowbottom Arshack, Hajek & Lehrman, PLLC 1790 Broadway, Suite 710 New York, New York 10019 Ph - 212-582-6500 Fax - 212-459-0568 Email - pat@lawahl.com . . . . From: Jennifer Piazza Sent: Friday, Novernber 15, 2019 12:27 PM To: Melie Botti ; Patricia Rowbottom ; Steven Garry Cc: levinengrossrñan aol com; Ginette Portera Subject: RE: Grayton v Bhayani - EBT of Dr Bhayani I think itwill probably be at a court reporting office in Brooklyn. 3 FILED: KINGS COUNTY CLERK 02/22/2021 04:47 PM INDEX NO. 508009/2013 NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 02/22/2021 Jennifer M. Piazza Office Manager Brown, Gaujean, Kraus & Sastow, PLLC - 10th One Building FlOOr 1 North - White NY 10601 Broadway Plains, 914.949.5300 - 914.949.6284 (T) (F) ipiazza@bgkslaw.corn www.baksiaw.com Attorneys at Law BROWN a GAUJEAN - KRAUS SASTOW, PLLC PRIVILEGED AND CONFIDENTIAL ATTORNEY CLIENT COMMUNICATION NOTICE: This communicationmay containprivileged or other information confidential intended to be for the use of the individual(s) named above.If you are not the intended or believe reciplent, that you have received this con müñ!Gt!en in error, please do not print, copy, d!esem!nete :::::::r.-.|t, or otherwiseuse this information. Please indicate to the sender that you have received this email in error and delete the copy that you have received.Thank you From: Melie Botti Sent: Friday, November 15, 2019 12:24 PM To: Jennifer Piazza ; PatriciaRowbottom ; Steven Garry Cc: levinengrossman@aol.com; Ginette Portera Subject: RE: Grayton v Bhayani - EBT of Dr Bhayani Jennifer - What's the location? From: Jennifer Piazza Sent: Friday, November 15, 2019 11:52 AM To: Melie Botti ; Patricia Rowbottom ; Steven Garry Cc: levinengrossman@aol.com; Ginette Portera Subject: RE: Grayton v Bhayani - EBT of Dr Bhayani It looks like December 9 at 12 pm is good for everyone, please confirm. Thanks! Jennifer M. Piazza Office Manager Brown, Gaujean, Kraus & Sastow, PLLC - 10th One Building Floor 1 North - White NY 10601 Broadway Plains, 914.949,5300 - 914.949.6284 (T) (F) jpiazza@bqkslaw.com www.b kslaw.com Attorneys at Law BROWN - GAUJEAN KRAUS • SASTOW, PLLC FILED: KINGS COUNTY CLERK 02/22/2021 04:47 PM INDEX NO. 508009/2013 NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 02/22/2021 PRIVILEGED AND CONFIDENTIAL ATTORNEY CL1ENT COMMUNICATION NOTICE: This cammür,|cation may containprMIeged or other confidential |ñfGrmät|Gn intended to be for the use of the|r.d|v|dsa|(a) narned above.If you are not the intended or belfeve that you have recipient, received this cGmmüñicätian please in error, do not print, copy, diccc.T.|nate or retransmit, otherwiseuse this information. Please indicate to the sender that you have received this email ln error and delete the copy that you have received.Thank you From: Melie Botti Sent: Friday, November 15, 2019 11:47 AM To: Jennifer Piazza ; Patricia Rowbottom ; Steven Garry Cc: levinengrossman@aol.com; Ginette Portera Subject: RE: Grayton v Bhayani - EBT of Dr Bhayani Hi Jenifer and everyone else- I spoke it's to get another - Can we Dec 9th -Than 11th I am not partner, okay attorney able to do fullcalendar. Please letme know -Thank youl From: Jennifer Piazza Sent: Friday, November 15, 2019 11:37 AM To: PatriciaRowbottom ; Steven Garry ; Melie Botti Cc: levinenqrossman@aol.com; Ginette Portera Subject: RE: Grayton v Bhayani - EBT of Dr Bhayani Not yet, I waS hoping Melie could see if someone in her office could do one of the other available dates that everyone else could do. Jennifer M. Piazza Office Manager Brown, Gaujean, Kraus & Sastow, PLLC • 10th One Building plOOr 1 North - White NY 10601 Broadway Plains, 914.949.5300 - 914.949.6284 (T) (F) jpiazza@bqkslaw.com www. kslaw.com Attorneys at Law BROWN - GAUJEAN - KRAUS SASTOW, PLLC PRIVILEGED AND CONFIDENTIAL ATTORNEY CLIENT COMMUNICATION NOTICE: This communicationmay containprivileged or other corifideñtiâ| to be for the use of the !nd!vidue!(s) infGrmst|Gn intended narned above. If you are not the intended recipient, that you have received or believe this ceiiiiiiüiiicätion in error, please do not print, copy, r*¤n9m!t disseminateor otherwiseuse this information. Please indicate to the sender that you have received in error and delete this email the copy that you have received.Thank you From: PatriciaRowbottom Sent: Thursday, November 14, 2019 3:09 PM To: Jennifer Plazza ; Steven Garry ; Melie Botti Cc: levinenqrossman@aol.com; Ginette Portera Subject: RE: Grayton v Bhayani - EBT of Dr Bhayani Did anything ever get scheduled ? 5 FILED: KINGS COUNTY CLERK 02/22/2021 04:47 PM INDEX NO. 508009/2013 NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 02/22/2021 PatriciaRowbottom Arshack, Hajek & Lehrman, PLLC 1790 Broadway, Suite 710 New York, New York 10019 Ph - 212-582-6500 Fax - 212-459-0568 Email - pat@Iawahl.com From: Jennifer Plazza Sent: Tuesday, November 12, 2019 1:34 PM To: PatriciaRowbottom ; Steven Garry ; Melie Botti Cc: levinenqrossman@aol.com; GInette Portera Subject: RE: Grayton v Bhayani - EBT of Dr Bhayani Melie, would you be able to see if maybe someone else in your office can be available on one of the other dates? Jennifer M. Plazza Office Manager Brown, Gaujean, Kraus & Sastow, PLLC - 10th One Building FlOOT 1 North = White NY 10601 Broadway Plains, 914.949.5300 - 914.949.6284 (T) (F) piazza@bqkslaw.com www-b kslaw.com Attorneys at Law BROWN • GAUJEAN KRAUS * SASTOW PLLC PRIVILEGED AND cONFIDENTIAL ATTORNEY CUENT COMMUNICATION NOTICE: This communicationmay contain or other confidential privileged information to be for the use of the |n±:!dus!(s) intended named above, If you are not the intended or believe that you have received recipient, this commurilcation do not print, copy, In error, please disseminate retransmIt, or otherwiseuse this information. Please Indicate to the sender that you have received this email in error and delete the copy that you have received.Thank you From: Patricia Rowbottom Sent: Tuesday, November 12, 2019 1:17 PM To: Steven Garry ; Melie Bottl; Jennifer Plazza <|plazza@bgkslaw.com> Cc: levinengrossman@aol.com; Ginette Portera Subject: RE: Grayton v Bhayani - EBT of Dr Bhayani We can do December 9 or 11th PatriciaRowbottom Arshack, Hajek & Lehrman, PLLC 1790 Broadway, Suite 710 New York, New York 10019 Ph - 212-582-6500 Fax - 212-459-0568 Email - pat@lawahl.com 6 FILED: KINGS COUNTY CLERK 02/22/2021 04:47 PM INDEX NO. 508009/2013 NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 02/22/2021 From: Steven Garry Sent: Tuesday, November 12, 2019 9:59AM To: Melie Botti ; Jennifer Piazza Cc: ley|ñeñqrossrñañ@aol.com; Patricia Rowbottom ; Ginette Portera Subject: RE: Grayton v Bhayani -EBT of Dr Bhayani I can do the 9th OF th. Bear In mind I believewe have another conference on 16th 4th, the Steven E. Garry Partner Costello, Shea & Gaffney LLP 100 Merrick Road East BIdg, Suite 218 Rockville Centre, New York 11570 Tel (212) 413-8902 Fax (516) 764-9104 sqarrv@csqllplaw.com From: Melie Bottifmailto:mbotti@schiavetti.com] Sent: Tuesday, November 12, 2019 9:53 AM To: Jennifer Piazza Cc: levinenqressrrianGaul.com; Steven Garry ; pat@lawahl.com; Ginette Portera Subject: RE: Grayton v Bhayani - EBT of Dr Bhayani Good Jennifer - The date that m attorney isavailab|e will be December 18th morning only -Sorry From: Jennifer Piazza Sent: Monday, November 11, 2019 2:59 PM To: Melie Botti Cc: levinengrossman@aol.com; sqarrv@csqllplaw.com; pat@iewahl.com; Ginette Portera Subject: RE: Grayton v Bhayani - EBT of Dr Bhayani Good afternoon. Please Consider the following dateS for the deposition of Dr. Bhayani: December 4, 9, 11, 18. We would need to start at 12 pm. Thank you. Jennifer M. Piazza Office Manager Brown, Gaujean, Kraus & Sastow, PLLC - 10th One Building Floor 1 North - White NY 10601 Broadway Plains, 914.949.5300 - 914.949.6284 (T) (F) jpiazza@bqkslaw.com www. ksiaw.com Attorneys at Law BROWN - GAUJEAN - KRAUS SASTOW, PLLC PRIVILEGED AND CONFIDENTIAL ATTORNEY CLIENT COMMUNICATION 7 FILED: KINGS COUNTY CLERK 02/22/2021 04:47 PM INDEX NO. 508009/2013 NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 02/22/2021 NOTICE: This ccmmüñ!cat!cñ privileged or other conf! " may contain nt!e! information Intended to be for the use of the ! ) named above.If you are not the intended recipient, that you have or believe received this e ::=ianon please In error, do not print, copy, disseminate retransmit, or oth6rw|56use this !nfermet!en. Please indicate that you have received to the sender this email In error and delete the copy that you have received.Thank you . . . From: Melie Botti Sent: Friday, October 25, 2019 12:41 PM To: Jennifer Piazza Cc: leviñangrossman@aol.com; sqarry@csq|lcFaw.com; pat@imv_ajn.cp.m; Ginette Portera Subject: Re: Grayton v Bhayani - EBT of Dr Bhayani Will get back to you need to see if theattorney can take the date Sent from my iPhone On Oct 25, 2019, at 12:11 PM, Jennifer Piazza wrote: Hi all. How about November 22 as a new date for Dr. Bhayani? Jennifer M. Piazza Office Manager Brown, Gaujean, Kraus & Sastow, PLLC • 10th One Building plOOr 1 North • White NY 10601 Broadway Plains, 914.949.5300 • 914.949.6284 (T) (F) jpiazza( bakslaw.com www.bqkslaw.com PRIVILEGED AND CONFIDENTIAL ATTORNEY CLIENT COMMUNICATION NOTICE: This communicationmay contain or other confident|al privileged Intended Information to be for the use of the individual(s) named above. If you are not the intended or believe that you have received recipient, this comrnunication in error, please do not print, copy. diesem!nete retransmit, or otherwise use this information. Please Indicate to the sender that you have received this email the copy that you have received. in error and delete Thank you From: levinengrossman@aol.com Sent: Tuesday, October 22, 2019 10:05 AM To: Jennifer Piazza ; sqarry@csqliplaw.com; oat@lawahl.com; mbotti@schiavetti.com Cc: Ginette Portera Subject: Re: Grayton v Bhayani -EBT of Dr Bhayani Good Morning, Sorry but I have to bustthe ebt my atty has a personnel matter that came up and he is not available tomorrow. Thanks Laura ---Original Message-- From: Jennifer Piazza To: levinenqrossman@aol.com ; soarrv@csailplaw.com ; oat |awahl.com ; Melie Botti Cc: Ginette Portera Sent: Tue, Oct 22, 2019 9:30 am Subject: RE: Grayton v Bhayani- EBT of Dr Bhayani Good morning all. We are prepared to go forward with Dr. Bhayani's deposition tomorrow. If everyone agrees, maybe we can do this at a court 8 FILED: KINGS COUNTY CLERK 02/22/2021 04:47 PM INDEX NO. 508009/2013 NYSCEF DOC. NO. 122 RECEIVED NYSCEF: 02/22/2021 reporting agency in Brooklyn near the courthouse? We can start at 10:30 AM. Let me know, thanks! Jennifer M. Plazza Office Manager Brown, Gaujean, Kraus & Sastow, PLLC - 10th One Building Floor 1 North - White NY 10601 Broadway Plains, 914.949.5300 - 914.949.6284 (T) (F) jpiazza bgkslaw.com www.bakslaw.com PRIVILEGED AND CONFIDENTIAL ATTORNEY CLIENT COMMUNICATION NOTICE: This communication may contain privileged infnrmanan or other confidential intendedto be for the use of the individual(s) named above. If you are not the intended or belIeve recipient, that you have received this communication In error, please do not print, copy, disseminate retransmit, or ctrierwise use this Information. Please to the sender that you have receIved this indicate emailin error and delete the copy that you have received.Thankyou From: Jennifer Piazza Sent: Friday, Septernber 27, 2019 10:48 AM To: levinenqrossman@aol.com; sqarry@csq[lplaw.com; pat@lawahi.com; Melie Botti Cc: Ginette Portera Subject: Grayton v Bhayani - EBT of Dr Bhayani Good morning everyone. Arshack's office was not available on 10/16. Can we please schedule Dr. Bhayani for 10/23? Thank you. Jennifer M. Piazza Office Manager Brown, Gaujean, Kraus & Sastow, PLLC - 10th One Building FlOOr 1 North - White NY 10601 Broadway Plains, 914.949.5300 - 914.949.6284 (T) (F) jpiazza@bqkslaw.com www.bgkslaw.com PRIVILEGED AND CONFIDENTIAL ATTORNEY CLIENT COMMUNICATION NOTICE: ThIs coi may contain ication or other confidential privileged !:± f!e-: intendedto be for the use of the !nd!v!due!(s) named above, If you are not the Intended or be[Ieve that you have received recipient, this comme:icet!on In error, please do not print, copy, disseminate retransmit, or otherwise use this information. Please indicate to the sender that you have received this emailin error and delete the copy that you have received. Thankyou 9