On May 24, 2018 a
Exhibit,Appendix
was filed
involving a dispute between
Atlantic Casualty Insurance Company,
and
Eastern Fruit & Vegetables Inc.,
for Commercial - Contract
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 06/14/2021 10:56 AM INDEX NO. 510798/2018
NYSCEF DOC. NO. 256 RECEIVED NYSCEF: 06/14/2021
From: Debra Krebs
To: blake@lblakemorris.com; info@lblakemorris.com
Subject: CORRESPONDENCE ATTACHED - Atlantic Casualty v. Eastern Fruit
Date: Friday, April 23, 2021 10:29:00 AM
Attachments: 2021-04-23 LT Morris re proposed order.pdf
Proposed Final Conference Part Order.pdf
Dear Mr. Morris,
Please see the attached correspondence and respond as soon as possible.
Thank you.
Debbie Krebs
Debra M. Krebs, Esq.
Keidel, Weldon & Cunningham, LLP
925 Westchester Avenue
Suite 400
White Plains, NY 10604
Tel: (914) 948-7000
(201) 490-7706
Fax: (914) 948-7010
dkrebs@kwcllp.com
Confidentiality: The information contained in this e-mail message is intended only for the
use of the individual or entity named above and is privileged and confidential. Any
dissemination, distribution, or copy of this communication other than to the individual or
entity named above is strictly prohibited. If you have received this communication in error,
please notify us immediately by telephone.
FILED: KINGS COUNTY CLERK 06/14/2021 10:56 AM INDEX NO. 510798/2018
NYSCEF DOC. NO. 256 RECEIVED NYSCEF: 06/14/2021
KEIDEL, WELDON & CUNNINGHAM, LLP
ATTORNEYS AT LAW
925 Westchester Avenue, Suite 400
White Plains, NY 10604
Telephone: (914) 948‐7000
Telefax: (914) 948‐7010 (Not for Service)
http://www.kwcllp.com
April 23, 2021
Via E-Mail and Regular Mail
L. Blake Morris, Esq.
1214 Cortelyou Rd.
Brooklyn, NY 12218-5404
RE: Atlantic Casualty Insurance Company v. Eastern Fruit & Vegetables Inc.
File No. 11999
Dear Mr. Morris:
Pursuant the Discovery Part rules of Hon. Lawrence Knipel, enclosed please find a
proposed Final Pre-Note Order. It is our understanding that the Court’s preclusion order is now
effective. As a result, we are not, at this point, pursuing the discovery from Defendant which was
previously ordered. We are not aware of any discovery requested by Defendant which is
outstanding. If you believe there is additional discovery outstanding beyond what is listed in the
proposed order, please let me know.
Kindly confirm your consent to the enclosed order. If I do not hear from you by
Wednesday, April 28, 2021 I will presume you do not consent and will proceed accordingly.
Thank you for your anticipated cooperation.
Very truly yours,
Debra M. Krebs
Encl.
WHITE PLAINS, NY ● NEW YORK, NY ● SYRACUSE, NY ● WILTON, CT
WARWICK, RI ● FAIR LAWN, NJ ● WYNCOTE, PA ● WILLISTON, VT ● NAPLES, FL
FILED: KINGS COUNTY CLERK 06/14/2021 10:56 AM INDEX NO. 510798/2018
NYSCEF DOC. NO. 256 RECEIVED NYSCEF: 06/14/2021
Hon. Lawrence Knipel
ATLANTIC CASUALTY INSURANCE COMPANY
510798/2018
EASTERN FRUIT & VEGETABLES INC.
June 22, 2021
N/A
N/A
N/A
N/A
Response to Plaintiff's subpoena to Anwarul Huque due on or before May 12, 2021
Defendant is precluded from testifying at trial or submitting affidavit in any dispositive motion as per this Court's order
dated March 19, 2021.
Keidel, Weldon & Cunningham, LLP Debra Krebs Atlantic Casualty Ins. Co.
FILED: KINGS COUNTY CLERK 06/14/2021 10:56 AM INDEX NO. 510798/2018
NYSCEF DOC. NO. 256 RECEIVED NYSCEF: 06/14/2021
From: Mail Delivery System
To: blake@lblakemorris.com; info@lblakemorris.com
Subject: Relayed: CORRESPONDENCE ATTACHED - Atlantic Casualty v. Eastern Fruit
Date: Friday, April 23, 2021 10:29:46 AM
Attachments: Message Headers.msg
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Document Filed Date
June 14, 2021
Case Filing Date
May 24, 2018
Category
Commercial - Contract
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FILED: KINGS COUNTY CLERK 06/14/2021 10:56 AM INDEX NO. 510798/2018 NYSCEF DOC. NO. 256 RECEIVED NYSCEF: 06/14/2021 From: Debra Krebs To: blake@lblakemorris.com; info@lblakemorris.com Subject: CORRESPONDENCE ATTACHED - Atlantic Casualty v. Eastern Fruit Date: Friday, April 23, 2021 10:29:00 AM Attachments: 2021-04-23 LT Morris re proposed order.pdf Proposed Final Conference Part Order.pdf Dear Mr. Morris, Please see the attached correspondence and respond as soon as possible. Thank you. Debbie Krebs Debra M. Krebs, Esq. Keidel, Weldon & Cunningham, LLP 925 Westchester Avenue Suite 400 White Plains, NY 10604 Tel: (914) 948-7000 (201) 490-7706 Fax: (914) 948-7010 dkrebs@kwcllp.com Confidentiality: The information contained in this e-mail message is intended only for the use of the individual or entity named above and is privileged and confidential. Any dissemination, distribution, or copy of this communication other than to the individual or entity named above is strictly prohibited. If you have received this communication in error, please notify us immediately by telephone. FILED: KINGS COUNTY CLERK 06/14/2021 10:56 AM INDEX NO. 510798/2018 NYSCEF DOC. NO. 256 RECEIVED NYSCEF: 06/14/2021 KEIDEL, WELDON & CUNNINGHAM, LLP ATTORNEYS AT LAW 925 Westchester Avenue, Suite 400 White Plains, NY 10604 Telephone: (914) 948‐7000 Telefax: (914) 948‐7010 (Not for Service) http://www.kwcllp.com April 23, 2021 Via E-Mail and Regular Mail L. Blake Morris, Esq. 1214 Cortelyou Rd. Brooklyn, NY 12218-5404 RE: Atlantic Casualty Insurance Company v. Eastern Fruit & Vegetables Inc. File No. 11999 Dear Mr. Morris: Pursuant the Discovery Part rules of Hon. Lawrence Knipel, enclosed please find a proposed Final Pre-Note Order. It is our understanding that the Court’s preclusion order is now effective. As a result, we are not, at this point, pursuing the discovery from Defendant which was previously ordered. We are not aware of any discovery requested by Defendant which is outstanding. If you believe there is additional discovery outstanding beyond what is listed in the proposed order, please let me know. Kindly confirm your consent to the enclosed order. If I do not hear from you by Wednesday, April 28, 2021 I will presume you do not consent and will proceed accordingly. Thank you for your anticipated cooperation. Very truly yours, Debra M. Krebs Encl. WHITE PLAINS, NY ● NEW YORK, NY ● SYRACUSE, NY ● WILTON, CT WARWICK, RI ● FAIR LAWN, NJ ● WYNCOTE, PA ● WILLISTON, VT ● NAPLES, FL FILED: KINGS COUNTY CLERK 06/14/2021 10:56 AM INDEX NO. 510798/2018 NYSCEF DOC. NO. 256 RECEIVED NYSCEF: 06/14/2021 Hon. Lawrence Knipel ATLANTIC CASUALTY INSURANCE COMPANY 510798/2018 EASTERN FRUIT & VEGETABLES INC. June 22, 2021 N/A N/A N/A N/A Response to Plaintiff's subpoena to Anwarul Huque due on or before May 12, 2021 Defendant is precluded from testifying at trial or submitting affidavit in any dispositive motion as per this Court's order dated March 19, 2021. Keidel, Weldon & Cunningham, LLP Debra Krebs Atlantic Casualty Ins. Co. FILED: KINGS COUNTY CLERK 06/14/2021 10:56 AM INDEX NO. 510798/2018 NYSCEF DOC. NO. 256 RECEIVED NYSCEF: 06/14/2021 From: Mail Delivery System To: blake@lblakemorris.com; info@lblakemorris.com Subject: Relayed: CORRESPONDENCE ATTACHED - Atlantic Casualty v. Eastern Fruit Date: Friday, April 23, 2021 10:29:46 AM Attachments: Message Headers.msg This is the mail system at host otransport-14.outbound.emailsrv.net. Your message was successfully delivered to the destination(s) listed below. If the message was delivered to mailbox you will receive no further notifications. Otherwise you may still receive notifications of mail delivery errors from other systems. The mail system : delivery via mx.lblakemorris.com.cust.b.hostedemail.com[64.98.36.4]:25: 250 2.0.0 Ok: queued as 0C38A1805C8BE : delivery via mx.lblakemorris.com.cust.b.hostedemail.com[64.98.36.4]:25: 250 2.0.0 Ok: queued as 0C38A1805C8BE