arrow left
arrow right
  • Pawflex Inc. v. International Warehouse Group Inc., Hartford Fire Insurance CompanyTorts - Other (negligence) document preview
  • Pawflex Inc. v. International Warehouse Group Inc., Hartford Fire Insurance CompanyTorts - Other (negligence) document preview
  • Pawflex Inc. v. International Warehouse Group Inc., Hartford Fire Insurance CompanyTorts - Other (negligence) document preview
  • Pawflex Inc. v. International Warehouse Group Inc., Hartford Fire Insurance CompanyTorts - Other (negligence) document preview
  • Pawflex Inc. v. International Warehouse Group Inc., Hartford Fire Insurance CompanyTorts - Other (negligence) document preview
  • Pawflex Inc. v. International Warehouse Group Inc., Hartford Fire Insurance CompanyTorts - Other (negligence) document preview
  • Pawflex Inc. v. International Warehouse Group Inc., Hartford Fire Insurance CompanyTorts - Other (negligence) document preview
  • Pawflex Inc. v. International Warehouse Group Inc., Hartford Fire Insurance CompanyTorts - Other (negligence) document preview
						
                                

Preview

FILED: KINGS COUNTY CLERK 08/09/2022 07:09 PM INDEX NO. 503015/2021 NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 08/09/2022 EXHIBIT E FILED: KINGS COUNTY CLERK 08/09/2022 07:09 PM INDEX NO. 503015/2021 NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 08/09/2022 Jeff Heydt From: Joanne Polk Sent: Tuesday, August 2, 2022 1:56 PM To: JeffHeydt Subject: FW: InventoryTransfer From: /O=FIRST ORGANIZATION/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=JOANNE POLK_IWG Sent: Tuesday, March 8, 2016 10:34 AM DiGrazia' Ingrati' To:'Jennifer ; 'Melissa ; pawflex 'joe@pawflex.com' Cc: Subject: RE: inventory Transfer It came in in 2014. That paperwork is in storage. The computer has itas the correct UPC #. But you're paperwork does not. So If you say that it is correct then we will ship that item. On this order. Thank You: Joanne Polk MacMurdo International Warehouse 290 Spagnoli Roacl Melville, NY 11747 IWG 0097 1 FILED: KINGS COUNTY CLERK 08/09/2022 07:09 PM INDEX NO. 503015/2021 NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 08/09/2022 631-694-4397 x305 631-844-0330- fax jpolk@intlwarehousing.com From: Jennifer DiGrazia [mailto_:jennifer@pawflex.com] Sent: Tuesday, March 08, 2016 10:31 AM To: Joanne Polk; 'Melissa Ingrati';pawflex Cc: jog@pawfl_ex.corn Subject: RE: Inventory Transfer This is the smallest size forthe OPP bags so this would be considered the 001 )ROTC001 PMJEC%WESLEEVE 81158602COCS 2XS ROTCOD OPP BAG- XXS- PROTECTIVE SLEEVE /COVER. UPC # 20811586020009 Melissa why is the highlight UPS that Joanne gave not lining up with the UPC on screen grab above? Joanne, I am sending a screen grab of all our UPCs for the OPP bags in an email to follow but for now take a look at the one just in question. Please let me know ifyou got any other discrepancies. Also please send me the original that you got these incorrect UPC codes from. This is obviously an issue ifsomeone here at PawFlex gave you wrong codes from the get go. Thanks, Jennifer The ultimate measure of a man isnot where he stands in moments of comfort, but where he stands at times of " challenge and controversy Martin Luther King, Jr. Jennifer DiGrazia. CEO Inc. 2604 i Brookly- PawFlex | East 28tnStreet N 1235 U SA Drect:+718 648-8685 I Mobile +718 887-6433 i Faxx718 615-2007 Email: Jennifer@aawflex.com lWeb wwwpawnex com Like us on facebook and become a fan! www.facebook.comipawflex B A N D A G E S CONFIL)ENT!AUTY NOT:CE: Th emotiis :tendedonly for or entity the person to whichit is addresseG Und mGy COmQin cor6den:mi and/or materio|. privilecec Any urtouthonzedreview. ordtstribution use, ciisclosure is pronibit°a the intended if you are not please recipient. contactthe sender by reply all copies of the onginal e mail and destroy message if you ore the intendea reapientbut de 1:ot wish to receive communications throughthis medium pleaseso advisemmediately. \WG0098 2 FILED: KINGS COUNTY CLERK 08/09/2022 07:09 PM INDEX NO. 503015/2021 NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 08/09/2022 From: Joanne Polk [nlailtodPolk@intlwllsegrp.com] Sent: Tuesday, March 08, 2016 9:59 AM Ingrati' To: Jennifer DiGrazia ; 'Melissa ; pawflex Cc: jpe@pawflex.com Subject: RE: Inventory Transfer We found something in the warehouse that says. OPP BAG- XXS- PROTECTIVE SLEEVE /COVER. UPC # 20811586020009 Would this be what you're looking for?? Doesn't match the UPC on your paperwork. I can't get into my system right now to check my inventory to see what item # we have it listed as. They're doing some updates and we are unable to enter right now. Thank You; Joanne Polk MacMurdo International Warehouse 290 Spagnoli Road Melville, NY 11747 631-694-4397 x305 631-844-0330- fax jpolk@intlwarehousing.com IWG 0099 3 FILED: KINGS COUNTY CLERK 08/09/2022 07:09 PM INDEX NO. 503015/2021 NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 08/09/2022 From: Jennifer DiGrazia [mailto:jennifer@pawflex.com] Sent: Monday, March 07, 2016 6:19 PM To: Joanne Polk; 'Melissa Ingrati';pawflex Cc: joe_@pawflex.com Subject: RE: Inventory Transfer To be more exact the 001's for the 2 items you mentioned are for XXS not XXXS. You should have this. Please letme know if you don't. Thanks " The ultimate measure of a man isnot where he stands in moments of comfort, but where he stands at times of " challenge and controversy Martin Luther King, Jr. Jennifer DiGrazia, CEO PawFlex Inc. I 2604 East28thStreetI NY 11235 Brooklyn. U.S A Direct: +718 648-8685 I Mobile:+718 887-6433 IFax:+718 615-2007 Email: Jennifer@pawflex.com ! Web: www pawflexcom Like us on facebook and become a fan! www.facebook.com/pawflex B A N D A G E S CONFIDENTIAUTY NOTICE: This emai!is intended or entity the person only for to which and may contain it is addressed ond,ior confidential material. privileged Any unauthorizedreview, or distributton use, disclosure is prohibited. If you ore not the intended p!eose contact rectpient the sender by reply all copies of the e mail ond destroy riginal message. If you ore the intended recipient but do not wish to receive communications through this medium. pleaseso advise smmediately. From: Joanne Polk [mailto:JPolk@jntlwhsegrp.com] Sent: Monday, March 07, 2016 4:37 PM To: Melissa Ingrati; pawflex Cc: Jennifer DiGrazia ; joe@_pawflex.con Subject: RE: Inventory Transfer We do not have stock on ROTC001 and ROMC001 Those items wont be on the transfer\ iwo 01oo 4 FILED: KINGS COUNTY CLERK 08/09/2022 07:09 PM INDEX NO. 503015/2021 NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 08/09/2022 Thank You; Joanne Polk MacMurdo International Warehouse 290 Spagnoli Road Melville, NY 11747 631-694-4397 x305 631-844-0330- fax jRolk@intlwarehousing.com From: Melissa Ingrati [mailto:melissa@p_a_wflex.com] Sent: Saturday, March 05, 2016 10:33 PM To: pawflex Cc: Jennifer DiGrazia; log pawftex.som Subject: Inventory Transfer Dear Joanne, Attached please find Transfer request. Please note that even though the transfer Inventory form was created to request individual cases, three inner cases equals one MASTER CARTON for each item. Please ensure that one master carton is pulled for each item. When this order is picked, please sign and date the form and send it back to me. Jennifer or Joe DiGrazia will be there this week to pick up this order. When I get the exact date, I will let you know. Thanks, Melissa 5 IWG 0101 FILED: KINGS COUNTY CLERK 08/09/2022 07:09 PM INDEX NO. 503015/2021 NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 08/09/2022 B A N D A G E S Melissa Ingrati, Invoicing Department PawFlex Inc. I 2604 East 28th Street I Brooklyn, NY 11235 U.S.A. Direct: +718 648-8685 I Mobile: +718 887-6433 I Fax: +718 615-2097 Email: Melissa@pawflex.com Web: www.pawflex.com Uke us on Facebook and become a fan! www.facebook.com/pawfiex CONFIDENTIALITY NOTICE: This email only for is intended the personor entity to which ond may it is addressed contain ond/or confidential privileged materlot.Any unauthorizedreview, or distribution use, disclosure is prohibited. If you ore not the intended please contact recipient, the senderby replye mallond destroyall copies of the original message. If you ore the intended but do not recipient wish to receive communications through this medium,please so advise immediately. IWG 0102 6 FILED: KINGS COUNTY CLERK 08/09/2022 07:09 PM INDEX NO. 503015/2021 NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 08/09/2022 Jeff Heydt From: JaclynCzamecki Sent: Monday, October 4,2021 11:36 AM To: JeffHeydt Subject: FW: Emailing:05-01-19 EOM Jaclyn Czamecki OfficeManager internationalWarehouse Group 290 Spagnoli Road Melville,New York 11747 (631)694-4397 x330 Fax(631)844-0330 iczamecki@intiarp.com . . .... . . ... _ ... .. .. .. . . Fem: Jaclyn Czamecki Sent: Wednesday, May 01, 2019 4:11 PM Mandy' To: 'JenniferDiGrazia'; Dods Chavez; 'Mandy Cc: pawflex; 'Steve Ragoonanan'; Michael Hecht Subject: RE: Emailing: 05-01-19 EOM Hi Jennifer, The palletthat is waitingto getpicked up has been deducted. I thought that we had saidall was kept as master cases. How did you count the OPP itemswhen you did inventory being the iIventory? Thank you. Jaclyn Czamecki Office Manager Intemational Warehouse Group 290 Spagnoli Road Melville,New York 11747 (631)694-4397 ×330 Fax(631)844-0330 iczarnecki@intlero.com - .... ........- ...-.. ........ .- . . .. . . . -. . - -.. .. From: Jennifer DIGrazia [mailto:jennifer@pawflex.com] Sent: Wednesday, May 01, 20199:56 AM Mandy' To: Doris Chavez;'Mandy Cc: powflex; 'Steve Ragoonanan'; Jaclyn Czamecid; Michael Hecht Subject: RE: Emailing: 05-01-19 EOM Thank you for your updated inventory. Please confirm thatyou are recording our OPP bag packaging as innercases not master cartons (3 innercases to 1 master carton). Also have you deducted the palletthat is waitingto be picked up yet or willyou do that afteritis pickedup? IWG 0016 FILED: KINGS COUNTY CLERK 08/09/2022 07:09 PM INDEX NO. 503015/2021 NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 08/09/2022 you 1.astly, can remove Melissa@pawflex.com from your contact list. She retired officially 2 weeks ago. Mandy has takingover her Job responsibilities pertaining to shipments. Please now copy; me (lennifer@pawflex.com) , mandv@pawflex.com and our new guy stevepDpawflex.com into correspondence. all Thanks, Jennifer Jennifer DIGrazia PawFlex Inc. I 2604 East 28th Street I Brooklyn, NY 11235 U.S.A. Direct:+718 648-8685 I Mobile: +718 887-6433 I Fax:+718 615-2097 Email:Jennifer@pawflex.com I Web: www.pawflex.com |faceBook www.facebook.com/pawflex CONFIDENTIALITY NOTICE: This email is intendedonly for the person or entityto which itis addressed and may contain confidential and/or privilegedmaterial. Any unauthorized review, use, disclosure ordistribution is prohibited.If youare not the intended recipient,please contact the sender by reply e mail and destroy allcopies of the originalmessage. If you are the intended recipientbut do notwish to receive communications through thismedium, please so advise immediately. -----OriginalMessage- From: Doris Chavez Sent: Wednesday, May 01,2019 9:32 AM Mandy' Ingrati' To: 'Mandy ; 'Melissa ; JenniferDiGrazia Cci pawflex Subject: Emailing: 05-01-19 EOM Your message is readyto be sent with the following fileorlink attachments: 05-01-19 EOM Note: To protect against computer viruses,e-mail programs may prevent sending or receivingcertain types of file attachments. Check your e-mail securitysettingsto determine how attachments are handled. TotalControlPanel Login To: lemmuckVshimlwhseprpann Remove this sender from my allowlist From; jennifor(iljpawnex.com You received this messa8e because tise sender is on your allow list 2 IWG 0017 FILED: KINGS COUNTY CLERK 08/09/2022 07:09 PM INDEX NO. 503015/2021 NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 08/09/2022 Jeff Heydt From: Jaclyn Czamecki Sent: Monday, October 4, 2021 11 37 AM To: JeffHeydt Subject: FW: Emailing: 05-01-19 EOM Jaclyn Czarnecki Office Manager International Warehouse Group 290 Spagnoll Road Melville,New York 11747 (631)694-4397 x330Fax(631)844-0330 iczarnecki@inttgro.com From: Jaclyn Czarnecid Sent: Wednesday, May 01, 2019 4:29 PM Mandy' To:.1ennifer DIGrazia; Doris Chaver, 'Mandy Cc: pawflex; 'Steve Ragoonanan'; Michael Hecht Subject: RE: Emailing: 05-01-19 EOM If youcounted masters then that is how I entered itand how it will be going forward. Thank you. Jaclyn Czarnecki OfficeManager internationalWarehouse Group 2M Spagnoli Road Melville,New York 11747 (631)694-4397 ×330 Fax(631)844-0330 iczarneckleintlero.com ._ . .. .. . - ..... .._...--.........-.._.. .... ... .-... _. . . ___ . . _. .. - - --.. .--. .. From: Jennifer DiGrazia [malito:jennifer@pawflex.com] Sent: Wednesday, May 01, 2019 4:27 PM Mandy' To: .1aclynCzarnecki; Doris Chavez; 'Mandy Cc: pawfiex; 'Steve Ragoonanan'; Michael Hecht Subject: RE: EmaIllng: 05-01-19 EOM We counted inmasters but in thepast you converted to inners on your pawflex inventory sheets so I justwanted to make sure we are on the same page and you would always keep Inventory amounts talliedin masters.Thanks, Jennifer Jennifer DIGrazia PawFlex Inc. IBrooklyn, NY 11235 U.S.A. I 2804 East 28th Street Dhect: +718 848-8685 I I Fac+718615-2097 Moblie: +718 887-6433 EmaD:JennifenAmawilex,com I Web: mow.ommnex.com |faceBook www.facebook.com/oawlten 1 IWG 0023 FILED: KINGS COUNTY CLERK 08/09/2022 07:09 PM INDEX NO. 503015/2021 NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 08/09/2022 Jeff Heydt From: Joanne Polk Sent: Tuesday, August 2,2022 1:43 PM To: JeffHeydt Subject: FW: Shortage Claim on Amazon PFBV000878 From: Joanne Polk Sent: Friday, November 12, 2021 4:21 PM To: Jeff Heydt Subject: FW: Shortage Claim on Amazon PFBV000878 From: /O=FIRST ORGANIZATION/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN:JOANNE POLK_IWG Sent: Tuesday, March 8, 2016 10:30 AM DiGrazia' Ingrati' To: 'Jennifer ; pawflex ; Donny Haffner Subject: RE: Shortage Claim on Amazon PFBV000878 Your order called for 24 pcs. We gave them 4 bags totaling 24 pcs. And put those in the box by themselves. I don't understand what they're missing? we shipped exactly what you asked us too. What are they saying they're short? IWG 0078 FILED: KINGS COUNTY CLERK 08/09/2022 07:09 PM INDEX NO. 503015/2021 NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 08/09/2022 Thank You; Joanne Polk MacMurdo International Warehouse 290 Spagnoli Road Melville, NY 11747 631-694-4397 x305 631-844-0330- fax jnolkñintlwarehousing.con) From: Jennifer DiGrazia [mailto:jennife_ridmawflex.com] Sent: Tuesday, March 08, 2016 10:19 AM To: Joanne Polk; 'Melissa Ingrati';pawflex; Donny Haffner Subject: RE: Shortage Claim on Amazon PFBV000878 See yellow in response to the infoyou provided ROMC003 means we shipped 4 bags. They were in a case by themselves. 4 ziplock bags are 24 units. A case of ROMC003 is 48 units(MC is medimitt cover) ROJ004CS means we shipped 6 bags and they were in a case by themselves. This is correct since the ROJ004 has 36 units per case " The ultimate measure of a man isnot where he stands in tr1oments of con1fort bt/twhere he stands at times of controversy." challenge ancI Martin Luther King Jr. Jennifer DiGrazia, CEO PawFlex Inc. i2604 East 28thStreet I NY 11235 Brooklyr., U.S.A. Direct: +718 648-8685 IMobile.+718 887-6433 IFax:+718 615-2097 Email: Jennifer@pawflex.com I Web www.pawftex.com Like us on facebook and become a fan! www.facebook.com/pawflex B A N D A G E S CONFiDENiiALITY NOT13: Thn eman15 intnded only forthe per5or or entitto wn:chit is addreswd ana incyCantmr confiderma;and/or or n:stritmiton recipien· cleasecor:ct te privilegea ma: ènƒ Any anourhorued evrev..use d scrasure is otMhivited ! you are not the in:ended sender by reply e mati and destroy cit coptes of rhe original message. 1- if you ore the totended b:n do not ipient wtsts to receive communications through so advise irninediately. this enedium, clease IWG 0079 2 FILED: KINGS COUNTY CLERK 08/09/2022 07:09 PM INDEX NO. 503015/2021 NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 08/09/2022 From: Joanne Polk [mailto:JPolk@intlwhsegrp.cog7] Sent: Tuesday, March 08, 2016 9:43 AM To: Melissa Ingrati; pawflex ; Donny Haffner Cc: Jennifer DiGrazia Subject: RE: Shortage Claim on Amazon PFBV000878 The LOOSE is a computer term. We're constantly having to open up cases and pull bags out because you don't ship full cases. so we put the extra bags in the system and write the word LOOSE. It means not a full case. SO on the order where I put LOOSE. Just means that in the system we had broken down full cases. BUT we shipped full cases on this order. The warehouse manager double checked this order before it left. ROMC003 means we shipped 4 bags. They were in a case by themselves. ROJ004CS means we shipped 6 bags and they were in a case by themselves. What items are they saying we short shipped them.?? Thank You: Joanne Polk MacMurdo International Warehouse 290 Spagnoli Road Melville, NY 11747 631-694-4397 x305 631-844-0330- fax IWG 0080 3