Preview
FILED: NEW YORK COUNTY CLERK 10/17/2022 04:03 PM INDEX NO. 602374/2009
NYSCEF DOC. NO. 132 RECEIVED NYSCEF: 10/17/2022
EXHIBIT D
FILED: NEW YORK COUNTY CLERK 10/17/2022 04:03 PM INDEX NO. 602374/2009
NYSCEF DOC. NO. 132 RECEIVED NYSCEF: 10/17/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
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STREET SNACKS, LLC,
Index No: 602374/09
Plaintiff,
AFFIRMATION
-against- IN OPPOSITION
OF AMY D.
BRIDGE ASSOCIATES OF SOHO, INC., CARLIN
ADAM D. LUCKNER, MIDWAY HOLDINGS CORP.,
YORK RESOURCES LLC, STERLING NATIONAL
BANK, NEW YORK STATE DISTRICT ATTORNEY, ORAL ARGUMENT
STATE OF NEW YORK, CITY OF NEW YORK, NEW REQUESTED
YORK CITY ENVIRONMENTAL CONTROL BOARD,
NEW YORK CITY DEPARTMENT OF FINANCE
and “JOHN DOES, Numbered 1 through 25,” the names
of the last twenty-five named defendants being fictitious,
real names unknown to plaintiff, the parties intended being
tenants or persons or corporations having an interest in as
tenants or persons in possession of portions of the mortgaged
premises,
Defendants.
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AMY D. CARLIN, an attorney duly admitted to practice law before the courts
and the State of New York, hereby affirms under penalty of perjury as follows:
1. I am a member of LaRocca Hornik Rosen Greenberg & Blaha LLP,
attorneys for plaintiff Street Snacks, LLC (“Street Snacks”). As such I am personally
familiar with the facts and circumstances stated herein. I make this affirmation in
opposition to the motion of defendants Bridge Associates of Soho, Inc. (“Bridge
Associates”) and Adam Luckner (hereinafter Bridge Associates and Adam D. Luckner
are collectively referred to as “Defendants”) to dismiss the complaint pursuant to CPLR
3215(c).
FILED: NEW YORK COUNTY CLERK 10/17/2022 04:03 PM INDEX NO. 602374/2009
NYSCEF DOC. NO. 132 RECEIVED NYSCEF: 10/17/2022
2. The evidence demonstrates that Street Snacks has not abandoned this
action to foreclose a commercial mortgage. From the outset, Bridge Associates and
Street Snacks sought to settle this lawsuit and reaching a global settlement would not
have been possible without holding the prosecution of this action in abeyance. In that
regard, Defendants are aware that Street Snacks has no intention of abandoning its claims
for repayment of the subject loan or this lawsuit.
3. On or about August 17, 2009, Street Snacks served the Complaint upon
Defendants. Shortly after being served, I received a telephone call from Alan Luckner
(“Alan”). Alan informed me that he was Adam Luckner’s father and an authorized
representative of Defendants. Alan is a sophisticated businessman with experience
developing and managing multi-family and mixed use properties in New York.
4. Alan advised me that Defendants were interested in exploring a possible
settlement of the lawsuit. He gave me his brief account of the subject loan’s history and
the primary property securing it, 533 Greenwich Street, New York, New York (the “NYC
Property”). Alan told me that he might be “looking to get out” of the NYC Property and
requested that my client and I meet with him and Robert Friedman, the principal of York
Resources LLC (“York”), to discuss possible settlement options. York is the holder of a
lien (the “York Mortgage”) on the NYC Property that is subordinate to Street Snacks’ lien.
5. On or about September 15, 2009, Thomas Makkos and I met with Alan
and Robert Friedman. Mr. Friedman is a lawyer and a well-established real estate
developer whose affiliated entities have substantial real estate holdings in New York. Alan
advised us that Mr. Friedman was also his close personal friend and that Bridge Associates
owed Mr. Friedman’s company approximately $700,000 in connection with the York
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Mortgage.
6. During the meeting, we discussed Street Snacks’ Note, the condition of
the NYC Property, and the obstacles Alan had experienced in dealing with the long-term
residents (the “Statutory Tenants”) who were on rent strike since 1990. Although we did
not discuss the material terms of a settlement at that initial meeting, the parties agreed to
continue to pursue the possibility of a settlement.
7. Following the meeting, I had numerous telephone conversations with Alan
concerning the NYC Property and the parameters for settlement. 1 Alan also requested
that Street Snacks extend Defendants’ time to answer or move in response to the
Complaint. Alan instructed me to send the letter confirming the extension to him by way
of an e-mail addressed to Allysa Nguyen, his daughter-in-law (and, upon information and
belief, Adam Luckner’s wife). See the letter with transmittal e-mail annexed hereto as
Exhibit A extending Defendants’ time to answer to October 29, 2009.
8. The settlement discussions culminated with Alan proposing to transfer the
NYC Property to Street Snacks through a deed in lieu of foreclosure. On or about
October 21, 2009, Alan confirmed the terms for the potential settlement, which included
(a) Bridge Associates transferring the NYC Property to Street Snacks through a deed in
lieu of foreclosure; (b) Street Snacks releasing Bridge Associates and the guarantors from
any liability for a deficiency; (c) York releasing and/or assigning the York Mortgage to
Street Snacks in exchange for Street Snacks’ installment payments of certain
consideration; (e) Street Snacks releasing its lien on the Woodmere Property and Long
Island Property; and (f) Street Snacks paying the closing costs for the transaction,
1
From the outset, Alan elected to take an informal approach to the lawsuit and settlement discussions,
handling the negotiations personally rather than retaining a lawyer.
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including the real estate transfer taxes and recording costs. The proposed terms were
subject York’s approval and any issues or conditions that arose during Street Snacks’ due
diligence and preparation for the closing of the transaction.
9. As a result of the ongoing settlement discussions, Street Snacks extended
Defendants’ time to respond to the Complaint to November 30, 2009. See the letter dated
October 23, 2009 with transmittal e-mail, annexed hereto as Exhibit B.
10. Initially, York demanded that Street Snacks provide York with security for
the installment payments in the form of a self-liquidating mortgage to be recorded against
the NYC Property. Street Snacks rejected York’s demand. After further negotiations,
Alan advised me that Robert Friedman agreed to accept the personal guaranties of Street
Snacks’ members as security for the payments.
11. With the terms of a settlement agreed to in principal, Street Snacks
undertook its due diligence and preparations for closing the transaction, including
investigating the conditions at the NYC Property, the scope of work and costs of repairs
to make the building code compliant, and curing any conditions that would prevent Street
Snacks from obtaining clear title to the property. I had numerous telephone conversations
with Alan concerning the many issues that had to be addressed prior to and/or at closing.
12. In that regard, the title report prepared in advance of the closing of the
transaction indicated that judgments totaling on excess of $26,000 and Environmental
Control Board violations totaling in excess of $50,000 were recorded against the NYC
Property. The title report also noted a recorded lease from 1977, a mortgage from 1962,
a mortgage from 1963, a mortgage from 1977, and a mortgage from 1985 that would
have to be resolved prior to closing. See the excerpts from the title report annexed hereto
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as Exhibit C.
13. In order to calculate the total consideration for purposes of paying the real
estate transfer taxes for the transaction, Street Snacks retained Michael Darling of Realty
Check, Inc. to appraise the NYC Property. The preliminary drafts of the appraisal did not
properly address the complicated circumstances surrounding the NYC Property that
would substantially impact its value. In that regard, Alan provided Mr. Darling with
certain information concerning the history of the building and his dealings with the
Statutory Tenants. See my e-mail to Allysa Nguyen dated June 25, 2010 advising Alan
that the appraiser would be contacting him, annexed hereto as Exhibit D.
14. Although Mr. Darling was retained in or about June 2010, the appraisal
was not finalized until almost one year later. See Mr. Darling’s transmittal e-mail to me
dated May 11, 2011, annexed hereto as Exhibit E.
15. As a result of Street Snacks’ increasing closing costs and the risks
associated with renovating, maintaining, and operating the NYC Property, it was agreed
that the consideration that Street Snacks was to pay to York would be reduced.
16. Because the closing of the transaction was still pending, rather than
continue to provide Defendants brief extensions of time to respond to the Complaint,
Alan requested that Street Snacks extend Defendants’ time to respond indefinitely. See
the letters with transmittal e-mails extending Defendants’ time to answer, annexed hereto
collectively as Exhibit F.
17. On September 14, 2011, Street Snacks extended Defendants’ time to
answer or move with respect to the Complaint “to a date that is twenty (20) days from the
date of service of a written demand for same.” See my letter with the transmittal e-mail
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thread, including Ms. Nguyen’s request that Defendants’ time to respond be expanded to
30 days upon demand, annexed hereto as Exhibit G.
18. Street Snacks further agreed that it would pay Bridge Associates an
amount toward the carrying costs of the NYC Property it was incurring while the
transaction was pending.
19. I continued to have regular telephone conversations with Alan discussing
the conditions at the NYC Property, the violations, the Statutory Tenants, the real estate
taxes and tax lien foreclosure action, and the transfer taxes that would be due at closing.
By way of example, see my e-mail to Alan dated November 20, 2012, annexed hereto as
Exhibit H.
20. In December 2012, I advised Alan that Street Snacks was prepared to
move forward to close the transaction for transferring the NYC Property with the deed in
lieu of foreclosure. See my follow-up e-mail to Brian Gallagher, Esq. dated December
17, 2012, annexed hereto as Exhibit I.2
21. Shortly thereafter, Alan contacted me directly to advise me that rather than
moving forward with the transaction to transfer the NYC Property to Street Snacks,
Bridge Associates intended to sell the NYC Property to a buyer and use the proceeds to
resolve, among other things, Street Snacks’ Note, real estate tax liens totaling over
$840,000, and the York Loan.
22. Alan told me that the transaction was dependent upon Bridge Associates
negotiating the purchase of all of the Statutory Tenants’ interests so that the buyer would
receive title to the vacant NYC Property. Although Street Snacks was prepared to close
2
Alan advised me that Mr. Gallagher, who regularly represented Robert Friedman in connection with his
companies’ real estate transactions, would be representing Bridge Associates at the closing.
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the deed in lieu of foreclosure transaction, Alan demanded that the settlement be put on
hold and that he be given time to complete the sale of the NYC Property. Alan contended
that not only would it be in Street Snacks’ financial interest to forebear from prosecuting
this lawsuit until the sale was completed, but that if Street Snacks did not, Bridge
Associates would file for bankruptcy protection which would delay any resolution.
23. Under the circumstances, Street Snacks agreed to provide Bridge
Associates with time to complete the transaction and achieve a global settlement.
24. I remained in close telephone contact with Alan and Robert Friedman
during the spring of 2013, monitoring the progress of their contract negotiations with the
buyer. In that regard, Mr. Friedman represented Bridge Associates in the pending
transaction.
25. On July 2, 2013, Mr. Friedman informed me that the due diligence period
provided in the parties’ contract of sale for the NYC Property had expired and that the
buyer was moving forward with the transaction. See the letter from Robert Friedman to
me annexed hereto as Exhibit J. Bridge Associates’ next step was to begin negotiations
with the Statutory Tenants to arrive at an amount acceptable to all parties for the
Statutory Tenants to vacate and surrender their rights. If the parties could not come to
such an agreement, the buyer had the right to cancel the contract. In his letter, Mr.
Friedman asked me to “stay in contact so I may keep you advised as to the progress of
discussions with the tenants and a likelihood of closing.”
26. Mr. Friedman advised me during his periodic updates that because Bridge
Associates was negotiating with the Statutory Tenants as a group rather than with each
individual tenant directly, the discussions were progressing very slowly.
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27. On September 4, 3013, Street Snacks provided Bridge Associates with an
itemization of the outstanding amounts due under the Note that would have to be
satisfactorily resolved as part of the global settlement. See my letter to Robert Friedman
dated September 4, 2013, annexed hereto as Exhibit K.
28. I remained in regular telephone contact with Mr. Friedman, generally
receiving bi-weekly updates on the status of his negotiations with the Statutory Tenants.
29. On April 2, 2014, Thomas Makkos and I met with Mr. Friedman to
discuss his negotiations with the Statutory Tenants and to also explore other possible
options for settling the amounts due from Bridge Associates to Street Snacks under the
Note. See the e-mail thread ending on March 29, 2014, annexed hereto as Exhibit L. At
the meeting, Mr. Friedman advised us that his negotiations with the Statutory Tenants
were on-going and that to date, nothing had arisen during his discussion with the
Statutory Tenants’ lawyer that would indicate that an agreement could not be reached.
30. Ultimately, Bridge Associates’ contract to sell the NYC Property to the
buyer terminated after Bridge Associates and the Statutory Tenants could not agree to a
purchase price for their interests. During a telephone conversation on or about September
8, 2014, Alan advised me that 50% of the Statutory Tenants demanded a higher purchase
price than Bridge Associates was able and/or willing to pay.
31. When I told Alan that Street Snacks was prepared to move forward with
the deed in lieu of foreclosure, he advised me that he had already taken steps to refinance
the liens on the NYC Property to enable Bridge Associates to develop the property with
the Statutory Tenants remaining in place. Alan represented that he was negotiating with
several private lenders interested in providing the necessary financing as joint venturers
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for the development of the building.
32. Alan continued to provide me with frequent updates until March 11, 2015,
when he informed me that Bridge Associates had a commitment to refinance the liens on
the NYC Property. In preparation for the anticipated transaction, he requested that Street
Snacks issue an updated pay-off letter for the amounts due under its Note. See my letter
to Alan dated March 27, 2015, annexed hereto as Exhibit M.
33. On or about April 29, 2015, Alan advised me that he was completing the
necessary paperwork for a loan in the amount of approximately $6.5 million that would
resolve the lawsuit and Note, satisfy the real estate tax liens, resolve the York Mortgage,
and pre-pay one year of interest. He advised me that the closing of the transaction was
scheduled for June 6, 2015.
34. On May 19, 2015, when I contacted Alan to obtain an update on the
transaction, he confirmed that the closing was still scheduled for June 6th, pending receipt
of an appraisal of the NYC Property. During our conversation, Alan identified the lender
as Kennedy Funding, a large private lender specializing in bridge loans for commercial
properties, who was introduced to Alan by Eastern Consolidated. Alan claimed that he
had already invested $35,000 in closing costs for the transaction and that the only delay
was the completion of the lender’s appraisal.
35. Ultimately, Bridge Associates’ transaction with Kennedy Funding
terminated as a result of the valuation placed on the NYC Property by the lender’s
appraiser. On September 21, 2015, Alan advised me that he believed that the lender’s
appraisal was unreasonably low and did not accurately reflect the NYC Property’s real
value. Alan told me that he was already working on negotiating a new arrangement to
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refinance the liens on the NYC Property with several interested private lenders
introduced to him by Adelaide Polsinelli of Eastern Consolidated and Rick Helfand of
Berko & Associates.
36. I attempted to contact Alan several times in late October 2015 seeking an
update on the proposed refinancing but I did not receive any response. Approximately
one week later, Defendants served the within motion.
37. The record established that after the lawsuit was filed and served, there
were constant communications between Street Snacks and Bridge Associates concerning
the settlement of this lawsuit, including the deed in lieu of foreclosure transaction, the
sale of the NYC Property, and the refinancing of the liens encumbering the NYC
Property. Each proposed settlement hinged on Street Snacks holding the prosecution of
this action in abeyance.
Defendants'
38. Street Snacks agreed to indefinitely extend time to answer the
Complaint in order to provide Defendants with the opportunity to resolve this matter.
Snacks'
Defendants are well aware that Street forbearance to pursue a judgment while
Defendants attempted to achieve a global settlement does not reflect any intention on the
part of Street Snacks to abandon this lawsuit or its claims for repayment of the subject
loan.
Defendants'
WHEREFORE, deponent respectfully requests that motion be denied
in itsentirety, and that Plaintiff be granted with such other and further relief as this Court
determines is just and proper.
Dated: New York, New York .. 7 c
December 21, 2015
AmÝ D. Carlin
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EXHIBIT A
FILED: NEW YORK COUNTY CLERK 10/17/2022 04:03 PM INDEX NO. 602374/2009
NYSCEF DOC. NO. 132 RECEIVED NYSCEF: 10/17/2022
Amy Carlin
From: Allysa Nguyen
Sent: Wednesday, september 16, 2009 1:53 PM
To: Amy Carlin
Subject: RE: Street Snacks, LLC v. Bridge Associates Of 50h0, Inc., et at
Attachments: letter.pdf
Please see attached.
Allysa Nguyen
Sheldon May & Associates, P.C.
255 ~
Merrick Road RockvilleCentre, New York 11570
- ~
Telephone: (516) 763 3200 Facsimile:(516) 763 -3243
Telephone: - ~ 394 - 4245
Direct (516) 394 4244 Direct Facsimile: (516)
THIS MESSAGEIS INTENDEDONLYFORTHE USEOF THE RECIPIENTTO WHOM IT IS ADDRESSED,AND MAY CONTAIN fNFORMATION THAT IS PRIVILEGED,
CONFIDENTIALAND EXEMPTFROM DISCLOSUREUNDERAPPLICABLELAW. IF THE READEROF THIS MESSAGEIS NOT THE INTENDED RECIPIENT,OR THE EMPLOYEEOR
AGENT RESPONSIBLE FORDELIVERINGTHE MESSAGETO THE INTENDED RECIPIENT,YOU ARE HEREBYNOTIFIEDTHAT ANY DISSEMINATION, DISTRIBUTIONOR
COPYINGOF THISCOMMUNICATION ISSTRICTLYPROHIBITED.IF YOU HAVE RECEIVEDTHISCOMMUNICATION IN ERROR,PLEASEDESTROYIT AND NOTIFY US
IMMEDIATELY BYTELEPHONEOR RETURNEMAIL.
Pursuant to IRSCircular 230, we hereby inform any U.S. federal tax advice set forth
you that herein was not intended
or written
by Sheldon May & Associates, P.C. to
may be imposed on you or any other person under the Internal
be used, and cannot be used, by you or any taxpayer, for the purpose of avoiding any penalties that
Revenue Code.
FNm: Amy Carlin [mailto:ACarlin@lhrgb.com]
Sent: Wednesday, September 16, 2009 1:36 PM
To: Allysa Nguyen
Subject: Street Snacks, LLC v. Bridge Associates of SohD, Inc., et al.
Pursuant to his instructions, please forward the attached letterto Alan Luckner.
Thank you.
LAROCCA HORN1K ROSEN
GREENBERG BLAÑA LLP
coomiumr uw
Amy D. Carlin,Esq.
The Trump Building
40 Wall Street, 32nd Floor
New York, NY 10005
Tel.(212) 530-4835
Fax (212) 530-4815
Email: ACARLIN@LHRGB.Ç0M
Please,don'tprintif youdon'thaveto
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NYSCEF DOC. NO. 132 RECEIVED NYSCEF: 10/17/2022
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FILED: NEW YORK COUNTY CLERK 10/17/2022 04:03 PM INDEX NO. 602374/2009
NYSCEF DOC. NO. 132 RECEIVED NYSCEF: 10/17/2022
LAROCCAH ORNIK ROSEN ÏG ifo u x
LAWR11NC)E
S.ROSEN
GREENBERG BLAHA LLP Ron cannao a
,, ERICl'liTER ELAMA
COUNSELORS AT LAW FLORENCLi
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65HARRISTOWNKOAD DAVID N. KtTTREDGEA
THE TRUM.PBUILDING 3M ROOK KARliNN. G RAYSON-RO
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40 WALL STREET -4N 2 ERINK. DDRKE
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FAX o cmmmuMau MomAtIn ATTORNEY
DIRECT DJAL: 212.530.4835
FRAIL; ӂ RLEERGB.COM
September 16, 2009
VIA EMAIL
allysa.nguyen@maylawfirm.com
Mr. Alan Luckner
619 Bridge Street
Woodmere, NY 11598
Re: Street Snacks, LLC v. Bridge Associates of Inc.
Soho,
Index No. 602374/09
Dear Mr. Luckner:
As you are aware, we represent plaintiff Street LLC in connection
Snacks, with the
referenced matter. This is to confirm that plaintiffhas agreed to to October
extend, 2, 2009, the
date by which defendants Bridge Associates of Adam D. Luckner
Soho, Inc., and Midway
Holdings Corp. must answer or move with respect to the Summons and Complaint.
Defendants hereby agree to waive any defenses have to service of the
they may
Complaint. Defendants further agree that a facsimile of thisletter shall be deemed to
copy have
the same force and effect as the original hereof.
Please arrange for the defendants to confirm that the isa correct statement
foregoing of
parties'
the agreement by having them sign thisletter in the spaces below and to
returning it us.
Very truly yours,
Amy D. Carlin
LMBWAmzkm1tr.9-3fAVAac
FILED: NEW YORK COUNTY CLERK 10/17/2022 04:03 PM INDEX NO. 602374/2009
NYSCEF DOC. NO. 132 RECEIVED NYSCEF: 10/17/2022
ACCEPTED AND AGREED:
BRIDGE ASSOCIATES OF SOHO, INC. ADAM D. LUCKNF,R
Title:
MIDWAY HOLDINGS CORP.
Title: ()x
LA1522L03VMtncr,lt.9-16.09Aac
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EXHIBIT B
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NYSCEF DOC. NO. 132 RECEIVED NYSCEF: 10/17/2022
Amy Carlin
From: Allysa Nguyen
Sent: Friday, October 23, 2009 10:36 AM
To: Amy Carlin
Subject: RE: Street Snacks LLC v. Bridge Associates of Soho, Inc.
Thanks!
. .
Allysa Nguyen
Sheldon May & AssociateS, P.C.
~
255 Merrick Road RockvilleCentre, New York 11570
- ~ -
Telephone: (516) 763 3200 Facsimile:(516) 763 3243
- ~ - 4245
Direct Telephone: (516) 394 4244 Direct FacSimile: (516) 394
THIS MESSAGEIS INTENDEDONLY FORTHE USEOF THE RECIPIENTTO WHOM IT IS ADDRESSED,AND MAY CONTAIN INFORMATION THAT IS PR1VlLEGED,
CONFIDENTIALAND EXEMPTFROM DISCLOSUREUNDERAPPuCABLELAW. IF THE READEROF THIS MESSAGEIS NOT THE INTENDED RECIPIENT,OR THE EMPLOYEEOR
AGENT RESPONSlBLEFORDEUVERINGTHE MESSAGETO THE INTENDED RECIPIENT,YOU ARE HEREBYNOTlFIEDTHAT ANY DISSEMINATION, DISTRIBUTIONOR
COPYINGOFTHIS COMMUNICATION ISSTRICTLYPROHIBITED.IF YOU HAVE RECEtVEDTHIS COMMUNICATION IN ERROR,PLEASEDESTROYIT AND NOTIFYUS
IMMEDIATELY BYTELEPHONEOR RETURNEMAIL.
Pursuant to IRSCircular 230, we hereby inform you that any U.S. federal tax advice set forth
herein was not intended
or written
by Sheldon May & Associates, P.C.to
be used, and cannot be used, by you or any taxpayer, for the purpose of avoiding any penalties that may be imposed on you or any other
person under the Internal
Revenue Code.
From: Amy Carlin [mailto:ACarlin@ihrgb.com]
Sent: Friday, October 23, 2009 9:48 AM
To: Allysa Nguyen
Subject: Street Snacks LLC v. Bridge Associates of Soho, Inc.
Please forward the attached letter to Alan Luckner.
Thank you.
LARoccA H ORN1K ROS EN
G R£iiN t1ERG LAHA LLP
edthnon Ar aw
Amy D. Cadin, Esq.
The Trump Building
40 Wall Street, 32nd Floor
New York, NY 10005
Tel.(212) 530-4835
Fa x (212)530-4815
Email: ACARLIN(d)LHRGB.COM
Please,don'tprintif youdon'thaveto
__________.----._______________------
This e-mail, and any attachments hereto, isintended only for use by the addressee(s) named herein and may contain
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notified that any dissemination, distribution or copying of thise-mail, and any attachments hereto, is prohibited.
strictly If
you have received this e-mail inerror, please immediately notifyme by reply e-mail and permanently delete the original
and any copy of thise-mail and any printout thereof. Finally, while the company uses virus protection, the recipient should
check this email and any attachments for the presence of viruses. The company accepts no for
liability any damage
caused by any virus transmitted by thisemail
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FILED: NEW YORK COUNTY CLERK 10/17/2022 04:03 PM INDEX NO. 602374/2009
NYSCEF DOC. NO. 132 RECEIVED NYSCEF: 10/17/2022
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