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  • Unitrin Advantage Insurance Company v. Aba Chiropractic, P.C., Apple Acupuncture, P.C., Auto Rx, L.C., Citimedical I, Pllc, Corona Medical Plaza, P.C., Elmont Rehab Pt, P.C., Ema Medical Equipment Corp., Fast Care Medical Diagnostics, Pllc, Frank S. Segreto, M.D., Health Balance Medical, P.C., Satya Drug Corp. D/B/A Farmacia Central, Ugp Acupuncture, P.C., Dwayne Corwise, Angela Salguedo Torts - Other (Declaratory Judgment) document preview
						
                                

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FILED: NEW YORK COUNTY CLERK 03/06/2019 04:50 PM INDEX NO. 154804/2017 NYSCEF DOC. NO. 98 RECEIVED NYSCEF: 03/06/2019 The Rybak Firm, PLLC 3rd 1810 Voorhies Avenue, Floor, Suite 7 Brooklyn, New York 11235 Telephone: 718 - 975 - 2035 Facsimile: 718 - 975 - 2037 Email: orybak@rybakfirm.com March 6, 2019 Goldberg Miller & Rubin HARLAN R. SCHREIBER, ESQ. 60 East 42nd Street, Suite 520, New York, NY 10165 Re: UNITRIN ADVANTAGE INSURANCE COMPANY v. ABA CHIROPRACTIC, P.C., etal. Index No.: 154804/17 Dear Mr. Schreiber: This letter is the =+ctan combined demands served on behalf of regarding ding discrsvery Defeñdañts, ELMONT REHAB PT, P.C., for the above-mentioned matter. Discovery demands must be responded to within twenty (20) days from date of receipt of such damanA. Please be advised that to this day, we have not received a response regarding such demands, although ample time has passed since such demands were served. Discovery is an important aspect of this action and in order to properly adjudicate this matter we must obtain the information requested. Pursuant to 22 NYCRR §202.7, this letter is an attempt to resolve this matter in good faith. Kindly provide the information requested for the above-meñtioñed matter within ten (10) days from the date of this letter. We would like to resolve this matter amicably; however, a failure to respond to this request will leave us no choice, but to seek judicial intervention and unnecessary motion practice. Thank you in advance for your prompt attention in this matter. Please do not hesitate to contact me at any time. Sincere y, Oleg bak, Esq. 1 of 1