Preview
FILED: NASSAU COUNTY CLERK 06/16/2022 05:22 PM INDEX NO. 001052/2019
NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 06/16/2022
EXHIBIT “9”
FILED: NASSAU COUNTY CLERK 06/16/2022 05:22 PM INDEX NO. 001052/2019
NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 06/16/2022
( 7 James Moran
Moran v. Grand Slam Ventures, LLC, et al., Index No. 001052-2019
1 message
James Moran Tue, Mar 29, 2022 at 12:48 PM
To: Richard Del Valle
Richard,
I hope allis well
with you and your family.
Please see attached and give me a call
to discuss same when you have a chance.
Thanks,
Jim
James Moran- Paralegal
(516)302-6581
PLEASE TAKE NOTICE: The information transmitted isintended only forthe person or to
entity which itisaddressed and may contain
confidentialand/orprivilegedmaterial.Any review, dissemination
retransmission, orotheruse of,or takingof any actionin reliance
upon, this
information personsor other
entities thanthe intendedrecipient
isprohibited.Ifyou receive transmission
this in error,
pleasecontactthe sender
by
immediately the material
and delete fromany computer.
----------------------
Discovery Letter 3-29-22.pdf
420K
FILED: NASSAU COUNTY CLERK 06/16/2022 05:22 PM INDEX NO. 001052/2019
NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 06/16/2022
JAMES MORAN
28 Carrie Avenue
Bethpage, New York 11714
Tel: (516) 302-6581
email: jim.catlawl @gmail.com
March 29, 2022
VIA EMAIL rdelvalle@siegelreiner.com
AND FIRST CLASS MAIL
Siegel & Reiner, LLP
Attorneys for Defendants
GRAND SLAM VENTURES, LLC,
JON STEINBERG, GLENN A. REINER
and JG REAL ESTATE VENTURES, LLC
59*
130 East Street, 12th Floor
New York, New York 10022
Tel: (212) 447-5599
Re: James Moran v. Grand Slam Ventures, LLC, Jon Steinberg, et al.,
Nassau County Index No.: 001052/2019
Mr. Del Valle,
As you are aware, pursuant to the Court's Order dated August 30, 2021, Defendants were
Ventures' Ventures'
required to produce defendant Grand Slam and defendant JG Real Estate
bank statements for the years 2012 through 2014.
You have represented that the Defendants are not in possession of their bank statements for
the years 2012 through 2014 and such are no longer available from the respective bank(s).
We conferenced this matter with the Court on February 9, 2022 and you affirmed that you
would provide an affidavit from a bank representative regarding defendant Grand Slam
Ventures' Ventures'
and defendant JG Real Estate bank statements which would include, but not
be limited to,how long the statements are retained by the bank, when they were destroyed and if
there was any litigation hold issued.
Also, pursuant to the Court's Order dated August 30, 202L Defendants were required to
provide sworn responses to certain of Plaintiff's interrogatories; specifically interrogatory
numbered 24 required Defendants to "State the consideration given and/or received to
relating
Page 1 of 2
FILED: NASSAU COUNTY CLERK 06/16/2022 05:22 PM INDEX NO. 001052/2019
NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 06/16/2022
the transfer of the real property commonly known as 219 Hempstead Turnpike, West
11552."
Hempstead, New York
Defendants'
As I have previously discussed with you, response to interrogatory
numbered 24 is cursory, superficial, woefully inadequate and totally unresponsive in clear
violation of the Court's Order.
During the Court conference and our conversations you affirmed that Defendants would be
providing a proper sworn statement as to the consideration given and/or received in response to
interrogatory numbered 24.
It has now been almost two months since the last Court conference and I not have received
the bank statements, the affidavit of a bank representative or a proper response to interrogatory
numbered 24.
Please advise when your clients will be complying with the Court's Order.
This letter is a good faith effort resolve discovery issues in accordance with 22 NYCRR
§202.7(a)(2), which provides that a not file a motion pertaining to discovery or a bill
party may
of particulars unless that has filed and served with its motion papers, "an affirmation that
party
counsel has conferred with counsel for the opposing party in a good faith effort to resolve the
motion."
issues raised by the
Should you have questions, or wish to discuss this matter further, please do not hesitate
any
to contact me.
Yours, et ,
JAMES . ORAN
Plaintiff pro se
Page 2 of 2
Preview
FILED: NASSAU COUNTY CLERK 06/16/2022 05:22 PM INDEX NO. 001052/2019 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 06/16/2022 EXHIBIT “9” FILED: NASSAU COUNTY CLERK 06/16/2022 05:22 PM INDEX NO. 001052/2019 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 06/16/2022 ( 7 James Moran Moran v. Grand Slam Ventures, LLC, et al., Index No. 001052-2019 1 message James Moran Tue, Mar 29, 2022 at 12:48 PM To: Richard Del Valle Richard, I hope allis well with you and your family. Please see attached and give me a call to discuss same when you have a chance. Thanks, Jim James Moran- Paralegal (516)302-6581 PLEASE TAKE NOTICE: The information transmitted isintended only forthe person or to entity which itisaddressed and may contain confidentialand/orprivilegedmaterial.Any review, dissemination retransmission, orotheruse of,or takingof any actionin reliance upon, this information personsor other entities thanthe intendedrecipient isprohibited.Ifyou receive transmission this in error, pleasecontactthe sender by immediately the material and delete fromany computer. ---------------------- Discovery Letter 3-29-22.pdf 420K FILED: NASSAU COUNTY CLERK 06/16/2022 05:22 PM INDEX NO. 001052/2019 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 06/16/2022 JAMES MORAN 28 Carrie Avenue Bethpage, New York 11714 Tel: (516) 302-6581 email: jim.catlawl @gmail.com March 29, 2022 VIA EMAIL rdelvalle@siegelreiner.com AND FIRST CLASS MAIL Siegel & Reiner, LLP Attorneys for Defendants GRAND SLAM VENTURES, LLC, JON STEINBERG, GLENN A. REINER and JG REAL ESTATE VENTURES, LLC 59* 130 East Street, 12th Floor New York, New York 10022 Tel: (212) 447-5599 Re: James Moran v. Grand Slam Ventures, LLC, Jon Steinberg, et al., Nassau County Index No.: 001052/2019 Mr. Del Valle, As you are aware, pursuant to the Court's Order dated August 30, 2021, Defendants were Ventures' Ventures' required to produce defendant Grand Slam and defendant JG Real Estate bank statements for the years 2012 through 2014. You have represented that the Defendants are not in possession of their bank statements for the years 2012 through 2014 and such are no longer available from the respective bank(s). We conferenced this matter with the Court on February 9, 2022 and you affirmed that you would provide an affidavit from a bank representative regarding defendant Grand Slam Ventures' Ventures' and defendant JG Real Estate bank statements which would include, but not be limited to,how long the statements are retained by the bank, when they were destroyed and if there was any litigation hold issued. Also, pursuant to the Court's Order dated August 30, 202L Defendants were required to provide sworn responses to certain of Plaintiff's interrogatories; specifically interrogatory numbered 24 required Defendants to "State the consideration given and/or received to relating Page 1 of 2 FILED: NASSAU COUNTY CLERK 06/16/2022 05:22 PM INDEX NO. 001052/2019 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 06/16/2022 the transfer of the real property commonly known as 219 Hempstead Turnpike, West 11552." Hempstead, New York Defendants' As I have previously discussed with you, response to interrogatory numbered 24 is cursory, superficial, woefully inadequate and totally unresponsive in clear violation of the Court's Order. During the Court conference and our conversations you affirmed that Defendants would be providing a proper sworn statement as to the consideration given and/or received in response to interrogatory numbered 24. It has now been almost two months since the last Court conference and I not have received the bank statements, the affidavit of a bank representative or a proper response to interrogatory numbered 24. Please advise when your clients will be complying with the Court's Order. This letter is a good faith effort resolve discovery issues in accordance with 22 NYCRR §202.7(a)(2), which provides that a not file a motion pertaining to discovery or a bill party may of particulars unless that has filed and served with its motion papers, "an affirmation that party counsel has conferred with counsel for the opposing party in a good faith effort to resolve the motion." issues raised by the Should you have questions, or wish to discuss this matter further, please do not hesitate any to contact me. Yours, et , JAMES . ORAN Plaintiff pro se Page 2 of 2