On February 08, 2021 a
Letter,Correspondence
was filed
involving a dispute between
Pawflex Inc.,
and
Hartford Fire Insurance Company,
International Warehouse Group Inc.,
for Torts - Other (negligence)
in the District Court of Kings County.
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October 8, 2021
By NYSCEF and Email
Honorable Richard J. Montelione, J.S.C.
Supreme Court, Kings County
360 Adams Street
Brooklyn, New York 11201
Re: Pawflex Inc. v. International Warehouse Group, Inc., et al.
Index No.: 503015/2021
Dear Judge Montelione:
This firm was retained yesterday by International Warehouse Group, Inc. (“IWG”) to
represent it in this matter.
The docket reflects that the plaintiff filed a motion for default judgment against IWG
on April 15, 2021, an appearance date of August 3, 2021, and that the motion is pending.
In light of my firm’s retention yesterday, I request that the Court grant a 30 day period
to assess the case with my client and for IWG to submit a response to the plaintiff’s pending
motion.
I have contacted the plaintiff’s counsel in an effort to obtain consent to this request.
The plaintiff’s counsel does not consent.
Your Honor’s consideration of this request is graciously appreciated.
Respectfully submitted,
Jonathan Bodner
For the Firm
cc: Scott Agulnick, Esq. (by NYSCEF and Email)
Michael Triosi, Esq. (by NYSCEF and Email)
Laura Gindele, Esq. (by NYSCEF and Email)
Document Filed Date
October 08, 2021
Case Filing Date
February 08, 2021
Category
Torts - Other (negligence)
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October 8, 2021 By NYSCEF and Email Honorable Richard J. Montelione, J.S.C. Supreme Court, Kings County 360 Adams Street Brooklyn, New York 11201 Re: Pawflex Inc. v. International Warehouse Group, Inc., et al. Index No.: 503015/2021 Dear Judge Montelione: This firm was retained yesterday by International Warehouse Group, Inc. (“IWG”) to represent it in this matter. The docket reflects that the plaintiff filed a motion for default judgment against IWG on April 15, 2021, an appearance date of August 3, 2021, and that the motion is pending. In light of my firm’s retention yesterday, I request that the Court grant a 30 day period to assess the case with my client and for IWG to submit a response to the plaintiff’s pending motion. I have contacted the plaintiff’s counsel in an effort to obtain consent to this request. The plaintiff’s counsel does not consent. Your Honor’s consideration of this request is graciously appreciated. Respectfully submitted, Jonathan Bodner For the Firm cc: Scott Agulnick, Esq. (by NYSCEF and Email) Michael Triosi, Esq. (by NYSCEF and Email) Laura Gindele, Esq. (by NYSCEF and Email)