On May 11, 2018 a
Exhibit,Appendix
was filed
involving a dispute between
Stella Stolper,
and
Zarina Burbacki,
for Commercial Division
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 07/08/2022 05:57 PM INDEX NO. 652352/2018
NYSCEF DOC. NO. 195 RECEIVED NYSCEF: 07/08/2022
jnesq@jenesqlaw.com
From: jnesq@jenesqlaw.com
Sent: Friday, May 13, 2022 1:39 PM
To: 'Rimma Ayzen'
Cc: 'Martin Russo'; 'Robert Sidorsky'; 'Racine Ramhurry'
Subject: RE: Stolper v Burbacki - deposition documents
Just to let you know, Zarina’s father was in the hospital, which delayed things. She is gathering the documents and is
almost finished.
LAW OFFICES OF JONATHAN E. NEUMAN, ESQ.
Jonathan E. Neuman, Esq.
176‐25 Union Turnpike, Suite 230
Fresh Meadows, NY 11366
(347) 450‐6710
THE CONTENT OF THIS E‐MAIL AND ANY ATTACHMENT(S) HERETO IS INFORMATION PROTECTED BY THE ATTORNEY‐
CLIENT AND/OR THE ATTORNEY WORK PRODUCT PRIVILEGE. IT IS INTENDED ONLY FOR THE VIEWING AND USE OF THE
INTENDED RECIPIENT AND PRIVILEGES ARE NOT WAIVED BY VIRTUE OF THIS HAVING BEEN SENT VIA E‐MAIL. IF THE
PERSON ACTUALLY RECEIVING THIS E‐MAIL OR ANY READER OF THIS E‐MAIL IS NOT THE NAMED RECIPIENT OR THE
EMPLOYEE OR AGENT RESPONSIBLE TO DELIVER THIS E‐MAIL TO THE NAMED RECIPIENT, THEN ANY USE,
DISSEMINATION, DISTRIBUTION OR COPYING THIS E‐MAIL OR ANY ATTACHMENT(S) IS STRICTLY PROHIBITED. IF YOU
RECEIVED THIS E‐MAIL IN ERROR PLEASE FORWARD IT BACK TO OUR E‐MAIL ADDRESS AT JNESQ@JENESQLAW.COM.
From: Rimma Ayzen
Sent: Monday, April 4, 2022 5:23 PM
To: jnesq@jenesqlaw.com
Cc: Martin Russo ; Robert Sidorsky ; Racine Ramhurry
Subject: RE: Stolper v Burbacki ‐ deposition documents
Jonathan:
This is in response to your email below. You failed to advise the Court that in response to your letter we provided a
detailed response to each of your document demands, and that you have yet to respond to our post‐deposition
discovery requests. Our position with regard to your document demands remains unchanged. As clearly delineated in
our letter, there are no additional documents to which your client is entitled and any motion seeking to compel such
documents would be a waste of the Court’s time and resources. On the other hand, there are glaring omissions in your
client’s production, as highlighted during her deposition, and we await your response to our post‐deposition document
requests.
Rimma Ayzen
RUSSO PLLC
350 Fifth Avenue, Suite 7230
New York NY 10118
+1 212 363 2000 www.russopllc.com
1
FILED: NEW YORK COUNTY CLERK 07/08/2022 05:57 PM INDEX NO. 652352/2018
NYSCEF DOC. NO. 195 RECEIVED NYSCEF: 07/08/2022
This email (and any attachments thereto) is intended only for use by the addressee(s) named herein and may contain legally privileged and/or
confidential information. If you are not the intended recipient of this email, you are hereby notified that any dissemination, distribution or
copying of this email (and any attachments thereto) is strictly prohibited. If you receive this email in error please immediately notify me
at (212) 363-2000 and permanently delete the original email (and any copy of any email) and any printout thereof.
From: jnesq@jenesqlaw.com
Sent: Sunday, April 3, 2022 2:17 PM
To: Racine Ramhurry
Cc: Rimma Ayzen ; Martin Russo ; Robert Sidorsky
Subject: RE: Stolper v Burbacki ‐ deposition documents
In light of the Court’s clear admonition to Rimma that Plaintiff’s position that it will not turn over post‐deposition
discovery is unacceptable, please let me know whether you will be producing the demanded documents, otherwise I will
file a motion. Thank you.
LAW OFFICES OF JONATHAN E. NEUMAN, ESQ.
Jonathan E. Neuman, Esq.
176‐25 Union Turnpike, Suite 230
Fresh Meadows, NY 11366
(347) 450‐6710
THE CONTENT OF THIS E‐MAIL AND ANY ATTACHMENT(S) HERETO IS INFORMATION PROTECTED BY THE ATTORNEY‐
CLIENT AND/OR THE ATTORNEY WORK PRODUCT PRIVILEGE. IT IS INTENDED ONLY FOR THE VIEWING AND USE OF THE
INTENDED RECIPIENT AND PRIVILEGES ARE NOT WAIVED BY VIRTUE OF THIS HAVING BEEN SENT VIA E‐MAIL. IF THE
PERSON ACTUALLY RECEIVING THIS E‐MAIL OR ANY READER OF THIS E‐MAIL IS NOT THE NAMED RECIPIENT OR THE
EMPLOYEE OR AGENT RESPONSIBLE TO DELIVER THIS E‐MAIL TO THE NAMED RECIPIENT, THEN ANY USE,
DISSEMINATION, DISTRIBUTION OR COPYING THIS E‐MAIL OR ANY ATTACHMENT(S) IS STRICTLY PROHIBITED. IF YOU
RECEIVED THIS E‐MAIL IN ERROR PLEASE FORWARD IT BACK TO OUR E‐MAIL ADDRESS AT JNESQ@JENESQLAW.COM.
From: Racine Ramhurry
Sent: Friday, March 18, 2022 12:08 PM
To: jnesq@jenesqlaw.com
Cc: Rimma Ayzen ; Martin Russo ; Robert Sidorsky
Subject: Stolper v Burbacki ‐ deposition documents
Dear Jonathan,
Please see attached.
Sincerely,
Racine Ramhurry
RUSSO PLLC
350 Fifth Avenue, Suite 7230
New York NY 10118
+1 212 363 2000 www.russopllc.com
2
FILED: NEW YORK COUNTY CLERK 07/08/2022 05:57 PM INDEX NO. 652352/2018
NYSCEF DOC. NO. 195 RECEIVED NYSCEF: 07/08/2022
This email (and any attachments thereto) is intended only for use by the addressee(s) named herein and may contain legally privileged and/or
confidential information. If you are not the intended recipient of this email, you are hereby notified that any dissemination, distribution or
copying of this email (and any attachments thereto) is strictly prohibited. If you receive this email in error please immediately notify me
at (212) 363-2000 and permanently delete the original email (and any copy of any email) and any printout thereof.
3
Document Filed Date
July 08, 2022
Case Filing Date
May 11, 2018
Category
Commercial Division
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Preview
FILED: NEW YORK COUNTY CLERK 07/08/2022 05:57 PM INDEX NO. 652352/2018 NYSCEF DOC. NO. 195 RECEIVED NYSCEF: 07/08/2022 jnesq@jenesqlaw.com From: jnesq@jenesqlaw.com Sent: Friday, May 13, 2022 1:39 PM To: 'Rimma Ayzen' Cc: 'Martin Russo'; 'Robert Sidorsky'; 'Racine Ramhurry' Subject: RE: Stolper v Burbacki - deposition documents Just to let you know, Zarina’s father was in the hospital, which delayed things. She is gathering the documents and is almost finished. LAW OFFICES OF JONATHAN E. NEUMAN, ESQ. Jonathan E. Neuman, Esq. 176‐25 Union Turnpike, Suite 230 Fresh Meadows, NY 11366 (347) 450‐6710 THE CONTENT OF THIS E‐MAIL AND ANY ATTACHMENT(S) HERETO IS INFORMATION PROTECTED BY THE ATTORNEY‐ CLIENT AND/OR THE ATTORNEY WORK PRODUCT PRIVILEGE. IT IS INTENDED ONLY FOR THE VIEWING AND USE OF THE INTENDED RECIPIENT AND PRIVILEGES ARE NOT WAIVED BY VIRTUE OF THIS HAVING BEEN SENT VIA E‐MAIL. IF THE PERSON ACTUALLY RECEIVING THIS E‐MAIL OR ANY READER OF THIS E‐MAIL IS NOT THE NAMED RECIPIENT OR THE EMPLOYEE OR AGENT RESPONSIBLE TO DELIVER THIS E‐MAIL TO THE NAMED RECIPIENT, THEN ANY USE, DISSEMINATION, DISTRIBUTION OR COPYING THIS E‐MAIL OR ANY ATTACHMENT(S) IS STRICTLY PROHIBITED. IF YOU RECEIVED THIS E‐MAIL IN ERROR PLEASE FORWARD IT BACK TO OUR E‐MAIL ADDRESS AT JNESQ@JENESQLAW.COM. From: Rimma Ayzen Sent: Monday, April 4, 2022 5:23 PM To: jnesq@jenesqlaw.com Cc: Martin Russo ; Robert Sidorsky ; Racine Ramhurry Subject: RE: Stolper v Burbacki ‐ deposition documents Jonathan: This is in response to your email below. You failed to advise the Court that in response to your letter we provided a detailed response to each of your document demands, and that you have yet to respond to our post‐deposition discovery requests. Our position with regard to your document demands remains unchanged. As clearly delineated in our letter, there are no additional documents to which your client is entitled and any motion seeking to compel such documents would be a waste of the Court’s time and resources. On the other hand, there are glaring omissions in your client’s production, as highlighted during her deposition, and we await your response to our post‐deposition document requests. Rimma Ayzen RUSSO PLLC 350 Fifth Avenue, Suite 7230 New York NY 10118 +1 212 363 2000 www.russopllc.com 1 FILED: NEW YORK COUNTY CLERK 07/08/2022 05:57 PM INDEX NO. 652352/2018 NYSCEF DOC. NO. 195 RECEIVED NYSCEF: 07/08/2022 This email (and any attachments thereto) is intended only for use by the addressee(s) named herein and may contain legally privileged and/or confidential information. If you are not the intended recipient of this email, you are hereby notified that any dissemination, distribution or copying of this email (and any attachments thereto) is strictly prohibited. If you receive this email in error please immediately notify me at (212) 363-2000 and permanently delete the original email (and any copy of any email) and any printout thereof. From: jnesq@jenesqlaw.com Sent: Sunday, April 3, 2022 2:17 PM To: Racine Ramhurry Cc: Rimma Ayzen ; Martin Russo ; Robert Sidorsky Subject: RE: Stolper v Burbacki ‐ deposition documents In light of the Court’s clear admonition to Rimma that Plaintiff’s position that it will not turn over post‐deposition discovery is unacceptable, please let me know whether you will be producing the demanded documents, otherwise I will file a motion. Thank you. LAW OFFICES OF JONATHAN E. NEUMAN, ESQ. Jonathan E. Neuman, Esq. 176‐25 Union Turnpike, Suite 230 Fresh Meadows, NY 11366 (347) 450‐6710 THE CONTENT OF THIS E‐MAIL AND ANY ATTACHMENT(S) HERETO IS INFORMATION PROTECTED BY THE ATTORNEY‐ CLIENT AND/OR THE ATTORNEY WORK PRODUCT PRIVILEGE. IT IS INTENDED ONLY FOR THE VIEWING AND USE OF THE INTENDED RECIPIENT AND PRIVILEGES ARE NOT WAIVED BY VIRTUE OF THIS HAVING BEEN SENT VIA E‐MAIL. IF THE PERSON ACTUALLY RECEIVING THIS E‐MAIL OR ANY READER OF THIS E‐MAIL IS NOT THE NAMED RECIPIENT OR THE EMPLOYEE OR AGENT RESPONSIBLE TO DELIVER THIS E‐MAIL TO THE NAMED RECIPIENT, THEN ANY USE, DISSEMINATION, DISTRIBUTION OR COPYING THIS E‐MAIL OR ANY ATTACHMENT(S) IS STRICTLY PROHIBITED. IF YOU RECEIVED THIS E‐MAIL IN ERROR PLEASE FORWARD IT BACK TO OUR E‐MAIL ADDRESS AT JNESQ@JENESQLAW.COM. From: Racine Ramhurry Sent: Friday, March 18, 2022 12:08 PM To: jnesq@jenesqlaw.com Cc: Rimma Ayzen ; Martin Russo ; Robert Sidorsky Subject: Stolper v Burbacki ‐ deposition documents Dear Jonathan, Please see attached. Sincerely, Racine Ramhurry RUSSO PLLC 350 Fifth Avenue, Suite 7230 New York NY 10118 +1 212 363 2000 www.russopllc.com 2 FILED: NEW YORK COUNTY CLERK 07/08/2022 05:57 PM INDEX NO. 652352/2018 NYSCEF DOC. NO. 195 RECEIVED NYSCEF: 07/08/2022 This email (and any attachments thereto) is intended only for use by the addressee(s) named herein and may contain legally privileged and/or confidential information. If you are not the intended recipient of this email, you are hereby notified that any dissemination, distribution or copying of this email (and any attachments thereto) is strictly prohibited. If you receive this email in error please immediately notify me at (212) 363-2000 and permanently delete the original email (and any copy of any email) and any printout thereof. 3