On October 30, 2017 a
Exhibit,Appendix
was filed
involving a dispute between
Sarah Rodriguez,
and
Cdc 111Th Street Realty, L.P.,
Cdc East 105Th Street Realty, L.P.,
for Torts - Other Negligence (Premises)
in the District Court of Bronx County.
Preview
FILED: BRONX COUNTY CLERK 09/30/2022 08:36 PM INDEX NO. 30287/2017E
NYSCEF DOC. NO. 40 RECEIVED NYSCEF: 09/30/2022
EXHIBIT I
FILED: BRONX COUNTY CLERK 09/30/2022 08:36 PM INDEX NO. 30287/2017E
NYSCEF DOC. NO. 40 RECEIVED NYSCEF: 09/30/2022
Emily Carlino (NY)
From: Emily Carlino (NY)
Sent: Wednesday, June 8, 2022 10:34 AM
To: John Giardino (NY)
Subject: FW: Rodriguez v.CDC East 105th Street - Stipulation
Realty
Attachments: Stipulation Time to Answer - Rodriguez v. CDC East 105th Street
Extending Realty
LP.docx
From: Frank Ross
Sent: Wednesday, June 8, 2022 10:33 AM
To: Emily Carlino (NY)
Cc: Frank Ross ; Peter Graff ; Dalia Ramos
; Justin Puderbach ; Charles E. Finelli
Subject: Re: Rodriguez v. CDC East 105th Street - Stipulation
Realty
CAUTION: Email from external account
"clean" "clean"
Interpose a answer now. No extension. We will consider withdrawing default motion once we have
answer in hand.
Respectfully,
Frank A. Ross
Law Offices of Charles E. Finelli
& Associates, PLLC
Sent from my iPhone
On Jun 8, 2022, at 10:26 AM, Emily Carlino (NY) wrote:
Emily Carlino
Legal Assistant
M R MICHELMAN & ROBINSON, LLP
New York [ Los Angeles
| OrangeCounty | San Francisco| Dallas
I Houston| Chicago
800 Third Avenue, 24th Floor,New York, NY 10022
T 212.730.7700 D 212.659.2576 F 212.730.7725
E ecarlino(d)mrllp.com www.mrllp.com
From: John Giardino (NY)
Sent: Wednesday, June 8, 2022 8:59 AM
1
FILED: BRONX COUNTY CLERK 09/30/2022 08:36 PM INDEX NO. 30287/2017E
NYSCEF DOC. NO. 40 RECEIVED NYSCEF: 09/30/2022
To: Emily Carlino (NY)
Cc: frank.ross@finelli.com
Subject: Re: Rodriguez v. CDC East 105th Street - Stipulation
Realty
Good morning Frank.
Can you reply by noon today.
Thank you,
John
John Giardino
T 212.730.7700 x 2587 D 212.659.2587
On Jun 7, 2022, at 3:49 PM, Emily Carlino (NY) wrote:
Dear Mr. Ross:
On behalf of Mr. Giardino, please find attached our proposed stipulation extending the
time to answer the complaint.
Thank you,
Emily
Emily Carlino
Legal Assistant
T 212.730.7700 x 2576 D 212.659.2576
2
Document Filed Date
September 30, 2022
Case Filing Date
October 30, 2017
Category
Torts - Other Negligence (Premises)
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Preview
FILED: BRONX COUNTY CLERK 09/30/2022 08:36 PM INDEX NO. 30287/2017E NYSCEF DOC. NO. 40 RECEIVED NYSCEF: 09/30/2022 EXHIBIT I FILED: BRONX COUNTY CLERK 09/30/2022 08:36 PM INDEX NO. 30287/2017E NYSCEF DOC. NO. 40 RECEIVED NYSCEF: 09/30/2022 Emily Carlino (NY) From: Emily Carlino (NY) Sent: Wednesday, June 8, 2022 10:34 AM To: John Giardino (NY) Subject: FW: Rodriguez v.CDC East 105th Street - Stipulation Realty Attachments: Stipulation Time to Answer - Rodriguez v. CDC East 105th Street Extending Realty LP.docx From: Frank Ross Sent: Wednesday, June 8, 2022 10:33 AM To: Emily Carlino (NY) Cc: Frank Ross ; Peter Graff ; Dalia Ramos ; Justin Puderbach ; Charles E. Finelli Subject: Re: Rodriguez v. CDC East 105th Street - Stipulation Realty CAUTION: Email from external account "clean" "clean" Interpose a answer now. No extension. We will consider withdrawing default motion once we have answer in hand. Respectfully, Frank A. Ross Law Offices of Charles E. Finelli & Associates, PLLC Sent from my iPhone On Jun 8, 2022, at 10:26 AM, Emily Carlino (NY) wrote: Emily Carlino Legal Assistant M R MICHELMAN & ROBINSON, LLP New York [ Los Angeles | OrangeCounty | San Francisco| Dallas I Houston| Chicago 800 Third Avenue, 24th Floor,New York, NY 10022 T 212.730.7700 D 212.659.2576 F 212.730.7725 E ecarlino(d)mrllp.com www.mrllp.com From: John Giardino (NY) Sent: Wednesday, June 8, 2022 8:59 AM 1 FILED: BRONX COUNTY CLERK 09/30/2022 08:36 PM INDEX NO. 30287/2017E NYSCEF DOC. NO. 40 RECEIVED NYSCEF: 09/30/2022 To: Emily Carlino (NY) Cc: frank.ross@finelli.com Subject: Re: Rodriguez v. CDC East 105th Street - Stipulation Realty Good morning Frank. Can you reply by noon today. Thank you, John John Giardino T 212.730.7700 x 2587 D 212.659.2587 On Jun 7, 2022, at 3:49 PM, Emily Carlino (NY) wrote: Dear Mr. Ross: On behalf of Mr. Giardino, please find attached our proposed stipulation extending the time to answer the complaint. Thank you, Emily Emily Carlino Legal Assistant T 212.730.7700 x 2576 D 212.659.2576 2