Preview
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’
s+ee--e= Original Message --------
Subject: Fwd: Baystar - 898 Sth Ave S
From: Kyle McLaughlin
Pate: Sun, September 02, 2018 3:18 pm
? Meredith@peckandpecklaw.com
Hi Meredith,
Per our conversation, please see below communication attempts and response from Alex Figares.
For disclosure purposes, I ask that you please keep the nature and my personal private information
confidential - this is not something I want disclosed to anyone.
Regards,
Kyle McLaughlin
From: Alex Figares
Date: Thu, Aug 30, 2018 at 9:28 AM
Subject: RE: Baystar - 898 Sth Ave S
To: kyle McLaughlin
Received.
Alex R. Figares, Esq.
The Northern Trust Building
4001 Tamiami ren Sulte 300
Naples, ida EMat ‘ K &
P: (230) 435-3535 | F: (239) 436-1218 COLEMAN | YOYANOVICH : KOESTER
afigares@eyklawfirm.com
Both Alex R. Figares and Coleman, Vovanovich & Koester, PA, intend that this message be used
eorciusively by the addresseets}.
Visit cyktawficm.com to learn more about US. Tus mesnigs may contain formation tht is privileged, confdentl, ad enmmpt from dione
under applicable law.
‘Unauthorized disclosure or use of this information is strictly prohibited. Hf you have received this
coramunication in error, please
dotify Alex R. Figares immediately st afsares@cviiawfism.com or call (239) 435-3535, and permanently dispose of the original message.
From: Kyle McLaughlin (mailto:kylemclayghlin127@gmail.com]
Sent: Wednesday, August 29, 2018 7:04 PM
To: Alex Figares ; CYKService
Subject: Re: Baystar - 898 Sth Ave S
Following up on this - please confirm receipt.
Thank you,
Kyle McLaughlin
239-641-1892EXHIBIT B—— Original Message ——-
Subject: Re: Fwd: Baystar - 898 Sth Ave S
From: Kyle McLaughlin
Date: Wed, September 05, 2018 10:28 am
To: Meredith Peck
Ill sign it - please update my address, I no longer live at river reach dr, havent for years
my address is 1378 Chesapeake Ave Naples, FL 34102
On Wed, Sep 5, 2018 at 10:23 AM Meredith Peck wrote:
You can, but he doesn't want to delay service if you are unwilling to sign the Acceptance of Service.
Meredith A. Peck, Esq.
Peck & Peck, P.A.
$200 Tamiami Trail North, Suite 101
Naples, Florida 34103
Telephone (239) 263-9811
Facsimile (239) 263-9818
For service of pleadings and court documents email: service@peckandpeckiaw.com
CONFIDENTIALITY NOTICE: The information contained in this transmission may be privileged and
confidential, and is intended only for the use of the individual or entity named above. If the reader of this
message is not the intended recipient, you are hereby notified that any dissemination, distribution or
copying of this communication is strictly prohibited. If you have received this transmission in error,
please immediately repiy to the sender that you have received this communication in error and then
delete it. Thank you.
srorenen Original Message --------
Subject: Re: Fwd: Baystar - 898 5th Ave S
From: Kyle McLaughlin
Date: Wed, September 05, 2018 10:17 am
To: Meredith Peck
By the Sherrif? 1 don’t understand, can I no longer sign what you sent me?
On Wed, Sep 5, 2018 at 9:54 AM Meredith Peck wrote:
T understand. I forwarded the correspondence to my client and he has instructed that we
proceed with formal service, so we will be doing so.
We will keep you updated on any progress with the landlord's counsel concerning the
proposed tenant.
Thank you,
Meredith A. Peck, Esq.
Pack & Peck, P.A.
5200 Tamiami Trail North, Suite 101.
Naples, Florida 34103
Telephone (239) 263-9811
Facsimile (239) 263-9818
For service of pleadings and court documents email: service@peckandpecklaw.com
CONFIDENTIALITY NOTICE: The information contained in this transmission may be privileged
3and confidential, and is intended only for the use of the individual or entity named above. If
the reader of this message is not the intended recipient, you are hereby notified that any
dissemination, distribution or copying of this communication is strictly prohibited. If you have
received this transmission in error, please immediately reply to the sender that you have
received this communication in error and then delete it. Thank you.
s------ Original Message --------
Subject: Re: Fwd: Baystar - 898 5th Ave S
From: Kyle McLaughlin
Date: Wed, September 05, 2018 9:34 am
To: Meredith Peck
Understood - I am simply requesting some more time before signing. That is all.
Please keep me updated on the response from their attorney - thank you
On Wed, Sep 5, 2018 at 9:32 AM Meredith Peck
wrote:
kyle,
I will pass along your comments to Danan, however, we have already filed the
Crossclaim with the Court and will be proceeding with service. If you are unwilling
to accept service and waive formal service of process, we will proceed with having
you served by the Sheriff and filing its return of service with the Court.
I will also be sending a follow up letter to the attorney for the landiord concerning
the tenant to see if we can work toward a resolution on this matter.
Best,
Meredith A. Peck, Esq.
Peck & Peck, P.A.
3200 Tamiami Trail North, Suite 101
Naples, Florida 34103
Telephone (239) 263-9811
Facsimile (239) 263-9818
For service of pleadings and court documents email: service@peckandpecklaw.com
CONFIDENTIALITY NOTICE: The information contained in this transmission may be
privileged and confidential, and is intended only for the use of the Individual or
entity named above. If the reader of this message is not the intended recipient, you
are hereby notified that any dissemination, distribution or copying of this
communication Is strictly prohibited. If you have received this transmission in error,
please immediately reply to the sender that you have received this communication
in error and then delete it. Thank you.
aeeenen= Original Message --------
Subject: Re: Fwd: Baystar - 898 Sth Ave S
From: Kyle McLaughlin
Date: Tue, September 04, 2018 5:34 pm
To: meredith@peckandpeckiaw.com
Yes, please proceed with follow up to the other attorney.
4In good faith, I feel that Delsing's suit against me is mislead and paints me
as breaching an agreement that was out of my control.
Marolax of Naples removed Danan from the lease as agreed, when the new
owner §98 Sth ave holdings (Hoffman) purchased the property, they
assumed the personal guarantee of myself and Danan - the agreement
signed at NABOR removed him from the lease, but not from the personal
guarantee - this suit has no merit against me.
To be completely honest with you, I want to keep this friendly - I still think
Danan is a great guy and I don't want this to be yet another smear on the
friendship we used to have - Im hoping you can help avoid him continuing
on this unnecessary suit against me.
T understand that he must have been extremely upset to receive the suit
from Hoffman, trust me, I was too considering I had been working on a
new tenant the whole time. There's really no reason to sue me here, the
reason the lease became delinquent is due to Jack Newby terminating me,
robbing me of almost $200K and shutting down all my vital
communications and access to leases and documentations - something Im
sure Danan remembers well as a he found himself in a similar situation
against Jack in early 2017.
Candidly, if Danan wants to file a suit, it should be against Jack, not me as
all of this was completely out of my control - I acted in good faith towards
Hoffman, and I acted in good faith towards Danan by attempting to reach
him multiple times when I found out about the sult, to which he never
replied.
At this point and time I would ask of you to please share my thoughts with
Mr. Delsing so we may come to a better resolution - I am still diligently
working with the Hoffman representatives to execute the new tenant's
lease; this should be happening within the next few weeks. Given all this
information, if Danan still wants to move forward with a suit against me,
then I respectfully ask that I am given until the end of this month
(September 2018) to sign the acceptance of service, as I am sure this will
all be resolved by then.
Either way, I hope to resolve this ASAP, as Im sure Danan does as well -
please past along my sincere best wishes to him and his family.
Thanks again for your time and explanation, seems like Danan hired a
great Attorney.
Best Regards,
Kyle McLaughlin
239-641-1892
On Tue, Sep 4, 2018 at 4:30 PM Meredith Peck
wrote:
Kyle,
Please confirm that I am permitted to follow up with the attorney
regarding the other tenant that is ready, willing and able to rent the
premises at the same amount that is due under the original lease. I will
then send him follow correspondence concerning the matter.
Also, as discussed, I attach to this e-mail a copy of the Answer,
Affirmative Defenses and Crossclaim filed in the matter along with an
acceptance of service for you to sign. If you accept service and waive
formal service of process, please sign and return the attached
5- Acceptance via e-mail. If you will not accept service, we will proceed
. With having a process server formally serve you with the documents.
* Sincerely,
Meredith A. Peck, Esq.
Pace Peck, PA sth Suite 101
Telephone (239) 263-9811
Facsimile (239) 263-9818
For service of pleadings and court documents
, email: service@peckandpecklaw.com
CONFIDENTIALITY NOTICE: The Information contained in this
transmission may be priviteged and confidential, and is intended only for
the use of the individual or entity named above. If the reader of this
message is not the intended recipient, you are hereby notified that any
dissemination, distribution or copying of this communication is strictly
prohibited. If you have received this transmission in error, please
immediately reply to the sender that you have received this
~ communication in error and then delete it. Thank you.
6EXHIBIT C—-—--— Original Message
Subject: Re: Fwd: Baystar - 898 Sth Ave S
From: Kyle McLaughlin
Date: Mon, October 29, 2018 5:29 pm
To: Meredith Peck
Attomey, broker was ccd on email
On Mon, Oct 29, 2018 at 5:28 PM Meredith Peck wrote:
Did you contact the broker you hired on the matter or are you attempting to correspond with the
attorney for the landlord?
Thanks,
Meredith A. Peck, Esq.
Peck & Peck, P.A.
Naples, Florida 34103
Telephone (239) 263-9811
Facsimile (239) 263-9818
For service of pleadings and court documents email: Service@peckandpecklaw.com
CONFIDENTIALITY NOTICE: The information contained in this transmission may be privileged and
Confidential, and is intended only for the use of the individual or entity named above. If the reader of this
message Is not the intended recipient, you are hereby notified that any dissemination, distribution or
Copying of this communication is strictly prohibited. If you have received this transmission in error,
please immediately reply to the sender that you have received this communication in evror and then
delete it. Thank you.
comcenee Original Message --------
Subject: Re: Fwd: Baystar -
From: Kyle McLaughlin <| >
Date: Mon, October 29, 2018 5:26 pm
To: Meredith Peck
T have not, I am waiting for a response to my email sent last week.
On Mon, Oct 29, 2018 at 5:25 PM Meredith Peck wrote:
Kyle,
Did you find out anything further about what happened with the tenant or the status of finding
another tenant?
Thanks,
Meredith A. Peck, Esq.
Peck & Peck, P.A.
3200 Tamiami Trail North, Suite 101
Naples, Florida 34103
Telephone (239) 263-9811
Facsimile (239) 263-9818
For service of pleadings and court documents email: Service@peckandpecklaw.com
4’ CONFIDENTIALITY NOTICE: The information contained in this transmission may be privileged
and confidential, and ts intended only for the use of the individual or entity named above. If
the reader of this message is not the intended recipient, you are hereby notified that any
dissemination, distribution or Copying of this communication is strictly prohibited. If you have
received this transmission in error, please immediately reply to the sender that you have
received this communication in error and then delete it. Thank you.
ceeeenne Original Message --------
Subject: Re: Fwd: Baystar - 898 5th Ave S
From: Kyle McLaughlin
Date: Tue, October 23, 2018 3:14 pm
To: Meredith Peck
Will do, thanks.
On Tue, Oct 23, 2018 at 3:13 PM Meredith Peck
wrote:
Kyle,
T am not aware who they are using. You may want to contact the broker you hired
to determine what has occurred regarding the other lease as I too was surprised
when opposing counsel advised that the deal fell apart. Please let me know what
you learn.
Thank you,
Meredith A. Peck, Esq.
Peck & Peck, P.A.
2200 Tamiami Trail North, Suite 101
Naples, Florida 34103
Telephone (239) 263-9811
Facsimile (239) 263-9818
For service of pleadings and court documents email: service@peckandpeckiaw.com
CONFIDENTIALITY NOTICE: The information contained in this transmission may be
Privileged and confidential, and is intended orily for the use of the individual or
entity named above. If the reader of this message Is not the intended recipient, you
are hereby notified that any dissemination, distribution or copying of this
communication is strictly prohibited. If you have received this transmission in error,
please immediately reply to the sender that you have received this communication
in error and then delete it. Thank you.
From: Kyle McLaughlin <, z >
Date: Tue, October 23, 2018 2:50 pm
To: Meredith Peck
Hi Meredith,
That comes as a surprise to me as last I heard they had an executed lease.
fDo you know if they are still using the broker I hired (CRE) or are they
using their own? That will determine whether or not I can get an update
for you as they have kept me pretty much removed from the entire
process,
Regards,
Kyle
On Tue, Oct 23, 2018 at 12:02 PM Meredith Peck
< > wrote:
Kyle,
Do you have any update as to what is occurring in this matter? My
understanding from speaking with counsel for the landlord is that the
tenant you located did not work out and that tenant leased another
: space elsewhere. Have you been in contact any further with the landlord
and do you have any other prospective tenants?
Thank you,
Meredith A. Peck, Esq.
Peck & Peck, P.A.
3200 Tamiami Trail North, Suite 101,
Naples, Florida 34103
Telephone (239) 263-9811
Facsimile (239) 263-9818
For service of pleadings and court documents
email: service@peckandnecklaw.com
CONFIDENTIALITY NOTICE: The Information contained in this
transmission may be privileged and Confidential, and is intended only for
the use of the individual or entity named above. If the reader of this
message Is not the intended recipient, you are hereby notified that any
dissemination, distribution or copying of this communication is strictly
Prohibited. If you have received this transmission in error, please
immediately reply to the sender that you have received this
Communication in error and then delete it. Thank you.
{0EXHIBIT Dwe
sre----- Original Message ------ ~
Subject: Re: Baystar - 898 Sth Ave S
From: Kyle McLaughlin
Date: Tue, November 27, 2018 2:02 pm
To: Meredith Peck
Tam willing to do that, however J need this default dismissed and would need indemnification from any
further claims from your client going forward
—@ Vius-free. www.avast.com
On Tue, Nov 27, 2018 at 1:59 PM Meredith Peck wrote:
Kyle,
Clarification - I meant to say that Danan is looking for you to indemnify and hold him harmless in regard
to the outstanding rent owed to the landlord, 898 Fifth Avenue Holdings, and to satisfy any rent
obligation. We sought the default to Protect Danan's interest, particularly because the landlord is
seeking judgment against Danan.
Thank you,
Meredith A. Peck, Esq.
Peck & Peck, P.A.
5200 Tamiami Trail North, Suite 101
Naples, Florida 34103
Telephone (239) 263-9811
Facsimile (239) 263-9818
For service of pleadings and court documents email: service@neckandpecklaw.com
CONFIDENTIALITY NOTICE: The information contained in this transmission may be privileged and
confidential, and ts intended only for the use of the individual or entity named above. If the reader of this
message is not the intended recipient, you are hereby notified that any dissemination, distribution or
please immediately reply to the sender that you have received this communication in error and then
delete it. Thank you.
z--eee-= Original Message --------
Subject: Re: Baystar - 898 Sth Ave S
From: Kyle McLaughlin <, 7. >
Date: Tue, November 27, 2018 1:32 pm
To: Meredith Peck
Meredith,
Did you ever consider to ask me if I would be willing to do that instead of going through the
trouble, wasted money and time to file for a default?
Additionally as clarification, there is no rent owed to Baystar nor is Baystar seeking rent from
Danan.
Please advise
IZ¢
“1g Virus-free. www.avast.com
On Tue, Nov 27, 2018 at 12:49 PM Meredith Peck wrote:
Kyle,
As you know, I represent Danan and his interest. Danan is looking for you to indemnify and
hold him harmtess in regard to the outstanding rent owed to Baystar and to satisfy any rent
obligation. To protect my client's interest, we sought the default, particularly since Baystar is
Sincerely,
Meredith A. Peck, Esq.
On Nov 27, 2018, at 11:42 AM, Kyle McLaughlin wrote:
Meredith,
A few things regarding this case that are extremely confusing.
1. T have been in constant communication with you in regards to what is going on
with Hoffmann - your request for default came as an absolute shock to me as I
have responded to all of your emails
2. What is Danan looking to accomplish by coming after me when this Is
completely out of my control? is he wanting to be dismissed from hoffmann's
suit?
3. As I mentioned before, Jack Newby, whom I am currently in another lawsuit
with, was the basis for this entire problem and was the only signer on that
NABOR agreement
As Ive mentioned before, I am willing to cooperate with you and Danan, but my
attempts so far have been unsuccessful with both him, and now you,
Please advise
Thanks,
Kyle McLaughlin
239-641-1892
13
Preview
ac ’ s+ee--e= Original Message -------- Subject: Fwd: Baystar - 898 Sth Ave S From: Kyle McLaughlin Pate: Sun, September 02, 2018 3:18 pm ? Meredith@peckandpecklaw.com Hi Meredith, Per our conversation, please see below communication attempts and response from Alex Figares. For disclosure purposes, I ask that you please keep the nature and my personal private information confidential - this is not something I want disclosed to anyone. Regards, Kyle McLaughlin From: Alex Figares Date: Thu, Aug 30, 2018 at 9:28 AM Subject: RE: Baystar - 898 Sth Ave S To: kyle McLaughlin Received. Alex R. Figares, Esq. The Northern Trust Building 4001 Tamiami ren Sulte 300 Naples, ida EMat ‘ K & P: (230) 435-3535 | F: (239) 436-1218 COLEMAN | YOYANOVICH : KOESTER afigares@eyklawfirm.com Both Alex R. Figares and Coleman, Vovanovich & Koester, PA, intend that this message be used eorciusively by the addresseets}. Visit cyktawficm.com to learn more about US. Tus mesnigs may contain formation tht is privileged, confdentl, ad enmmpt from dione under applicable law. ‘Unauthorized disclosure or use of this information is strictly prohibited. Hf you have received this coramunication in error, please dotify Alex R. Figares immediately st afsares@cviiawfism.com or call (239) 435-3535, and permanently dispose of the original message. From: Kyle McLaughlin (mailto:kylemclayghlin127@gmail.com] Sent: Wednesday, August 29, 2018 7:04 PM To: Alex Figares ; CYKService Subject: Re: Baystar - 898 Sth Ave S Following up on this - please confirm receipt. Thank you, Kyle McLaughlin 239-641-1892EXHIBIT B—— Original Message ——- Subject: Re: Fwd: Baystar - 898 Sth Ave S From: Kyle McLaughlin Date: Wed, September 05, 2018 10:28 am To: Meredith Peck Ill sign it - please update my address, I no longer live at river reach dr, havent for years my address is 1378 Chesapeake Ave Naples, FL 34102 On Wed, Sep 5, 2018 at 10:23 AM Meredith Peck wrote: You can, but he doesn't want to delay service if you are unwilling to sign the Acceptance of Service. Meredith A. Peck, Esq. Peck & Peck, P.A. $200 Tamiami Trail North, Suite 101 Naples, Florida 34103 Telephone (239) 263-9811 Facsimile (239) 263-9818 For service of pleadings and court documents email: service@peckandpeckiaw.com CONFIDENTIALITY NOTICE: The information contained in this transmission may be privileged and confidential, and is intended only for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this transmission in error, please immediately repiy to the sender that you have received this communication in error and then delete it. Thank you. srorenen Original Message -------- Subject: Re: Fwd: Baystar - 898 5th Ave S From: Kyle McLaughlin Date: Wed, September 05, 2018 10:17 am To: Meredith Peck By the Sherrif? 1 don’t understand, can I no longer sign what you sent me? On Wed, Sep 5, 2018 at 9:54 AM Meredith Peck wrote: T understand. I forwarded the correspondence to my client and he has instructed that we proceed with formal service, so we will be doing so. We will keep you updated on any progress with the landlord's counsel concerning the proposed tenant. Thank you, Meredith A. Peck, Esq. Pack & Peck, P.A. 5200 Tamiami Trail North, Suite 101. Naples, Florida 34103 Telephone (239) 263-9811 Facsimile (239) 263-9818 For service of pleadings and court documents email: service@peckandpecklaw.com CONFIDENTIALITY NOTICE: The information contained in this transmission may be privileged 3and confidential, and is intended only for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this transmission in error, please immediately reply to the sender that you have received this communication in error and then delete it. Thank you. s------ Original Message -------- Subject: Re: Fwd: Baystar - 898 5th Ave S From: Kyle McLaughlin Date: Wed, September 05, 2018 9:34 am To: Meredith Peck Understood - I am simply requesting some more time before signing. That is all. Please keep me updated on the response from their attorney - thank you On Wed, Sep 5, 2018 at 9:32 AM Meredith Peck wrote: kyle, I will pass along your comments to Danan, however, we have already filed the Crossclaim with the Court and will be proceeding with service. If you are unwilling to accept service and waive formal service of process, we will proceed with having you served by the Sheriff and filing its return of service with the Court. I will also be sending a follow up letter to the attorney for the landiord concerning the tenant to see if we can work toward a resolution on this matter. Best, Meredith A. Peck, Esq. Peck & Peck, P.A. 3200 Tamiami Trail North, Suite 101 Naples, Florida 34103 Telephone (239) 263-9811 Facsimile (239) 263-9818 For service of pleadings and court documents email: service@peckandpecklaw.com CONFIDENTIALITY NOTICE: The information contained in this transmission may be privileged and confidential, and is intended only for the use of the Individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication Is strictly prohibited. If you have received this transmission in error, please immediately reply to the sender that you have received this communication in error and then delete it. Thank you. aeeenen= Original Message -------- Subject: Re: Fwd: Baystar - 898 Sth Ave S From: Kyle McLaughlin Date: Tue, September 04, 2018 5:34 pm To: meredith@peckandpeckiaw.com Yes, please proceed with follow up to the other attorney. 4In good faith, I feel that Delsing's suit against me is mislead and paints me as breaching an agreement that was out of my control. Marolax of Naples removed Danan from the lease as agreed, when the new owner §98 Sth ave holdings (Hoffman) purchased the property, they assumed the personal guarantee of myself and Danan - the agreement signed at NABOR removed him from the lease, but not from the personal guarantee - this suit has no merit against me. To be completely honest with you, I want to keep this friendly - I still think Danan is a great guy and I don't want this to be yet another smear on the friendship we used to have - Im hoping you can help avoid him continuing on this unnecessary suit against me. T understand that he must have been extremely upset to receive the suit from Hoffman, trust me, I was too considering I had been working on a new tenant the whole time. There's really no reason to sue me here, the reason the lease became delinquent is due to Jack Newby terminating me, robbing me of almost $200K and shutting down all my vital communications and access to leases and documentations - something Im sure Danan remembers well as a he found himself in a similar situation against Jack in early 2017. Candidly, if Danan wants to file a suit, it should be against Jack, not me as all of this was completely out of my control - I acted in good faith towards Hoffman, and I acted in good faith towards Danan by attempting to reach him multiple times when I found out about the sult, to which he never replied. At this point and time I would ask of you to please share my thoughts with Mr. Delsing so we may come to a better resolution - I am still diligently working with the Hoffman representatives to execute the new tenant's lease; this should be happening within the next few weeks. Given all this information, if Danan still wants to move forward with a suit against me, then I respectfully ask that I am given until the end of this month (September 2018) to sign the acceptance of service, as I am sure this will all be resolved by then. Either way, I hope to resolve this ASAP, as Im sure Danan does as well - please past along my sincere best wishes to him and his family. Thanks again for your time and explanation, seems like Danan hired a great Attorney. Best Regards, Kyle McLaughlin 239-641-1892 On Tue, Sep 4, 2018 at 4:30 PM Meredith Peck wrote: Kyle, Please confirm that I am permitted to follow up with the attorney regarding the other tenant that is ready, willing and able to rent the premises at the same amount that is due under the original lease. I will then send him follow correspondence concerning the matter. Also, as discussed, I attach to this e-mail a copy of the Answer, Affirmative Defenses and Crossclaim filed in the matter along with an acceptance of service for you to sign. If you accept service and waive formal service of process, please sign and return the attached 5- Acceptance via e-mail. If you will not accept service, we will proceed . With having a process server formally serve you with the documents. * Sincerely, Meredith A. Peck, Esq. Pace Peck, PA sth Suite 101 Telephone (239) 263-9811 Facsimile (239) 263-9818 For service of pleadings and court documents , email: service@peckandpecklaw.com CONFIDENTIALITY NOTICE: The Information contained in this transmission may be priviteged and confidential, and is intended only for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this transmission in error, please immediately reply to the sender that you have received this ~ communication in error and then delete it. Thank you. 6EXHIBIT C—-—--— Original Message Subject: Re: Fwd: Baystar - 898 Sth Ave S From: Kyle McLaughlin Date: Mon, October 29, 2018 5:29 pm To: Meredith Peck Attomey, broker was ccd on email On Mon, Oct 29, 2018 at 5:28 PM Meredith Peck wrote: Did you contact the broker you hired on the matter or are you attempting to correspond with the attorney for the landlord? Thanks, Meredith A. Peck, Esq. Peck & Peck, P.A. Naples, Florida 34103 Telephone (239) 263-9811 Facsimile (239) 263-9818 For service of pleadings and court documents email: Service@peckandpecklaw.com CONFIDENTIALITY NOTICE: The information contained in this transmission may be privileged and Confidential, and is intended only for the use of the individual or entity named above. If the reader of this message Is not the intended recipient, you are hereby notified that any dissemination, distribution or Copying of this communication is strictly prohibited. If you have received this transmission in error, please immediately reply to the sender that you have received this communication in evror and then delete it. Thank you. comcenee Original Message -------- Subject: Re: Fwd: Baystar - From: Kyle McLaughlin <| > Date: Mon, October 29, 2018 5:26 pm To: Meredith Peck T have not, I am waiting for a response to my email sent last week. On Mon, Oct 29, 2018 at 5:25 PM Meredith Peck wrote: Kyle, Did you find out anything further about what happened with the tenant or the status of finding another tenant? Thanks, Meredith A. Peck, Esq. Peck & Peck, P.A. 3200 Tamiami Trail North, Suite 101 Naples, Florida 34103 Telephone (239) 263-9811 Facsimile (239) 263-9818 For service of pleadings and court documents email: Service@peckandpecklaw.com 4’ CONFIDENTIALITY NOTICE: The information contained in this transmission may be privileged and confidential, and ts intended only for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or Copying of this communication is strictly prohibited. If you have received this transmission in error, please immediately reply to the sender that you have received this communication in error and then delete it. Thank you. ceeeenne Original Message -------- Subject: Re: Fwd: Baystar - 898 5th Ave S From: Kyle McLaughlin Date: Tue, October 23, 2018 3:14 pm To: Meredith Peck Will do, thanks. On Tue, Oct 23, 2018 at 3:13 PM Meredith Peck wrote: Kyle, T am not aware who they are using. You may want to contact the broker you hired to determine what has occurred regarding the other lease as I too was surprised when opposing counsel advised that the deal fell apart. Please let me know what you learn. Thank you, Meredith A. Peck, Esq. Peck & Peck, P.A. 2200 Tamiami Trail North, Suite 101 Naples, Florida 34103 Telephone (239) 263-9811 Facsimile (239) 263-9818 For service of pleadings and court documents email: service@peckandpeckiaw.com CONFIDENTIALITY NOTICE: The information contained in this transmission may be Privileged and confidential, and is intended orily for the use of the individual or entity named above. If the reader of this message Is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this transmission in error, please immediately reply to the sender that you have received this communication in error and then delete it. Thank you. From: Kyle McLaughlin <, z > Date: Tue, October 23, 2018 2:50 pm To: Meredith Peck Hi Meredith, That comes as a surprise to me as last I heard they had an executed lease. fDo you know if they are still using the broker I hired (CRE) or are they using their own? That will determine whether or not I can get an update for you as they have kept me pretty much removed from the entire process, Regards, Kyle On Tue, Oct 23, 2018 at 12:02 PM Meredith Peck < > wrote: Kyle, Do you have any update as to what is occurring in this matter? My understanding from speaking with counsel for the landlord is that the tenant you located did not work out and that tenant leased another : space elsewhere. Have you been in contact any further with the landlord and do you have any other prospective tenants? Thank you, Meredith A. Peck, Esq. Peck & Peck, P.A. 3200 Tamiami Trail North, Suite 101, Naples, Florida 34103 Telephone (239) 263-9811 Facsimile (239) 263-9818 For service of pleadings and court documents email: service@peckandnecklaw.com CONFIDENTIALITY NOTICE: The Information contained in this transmission may be privileged and Confidential, and is intended only for the use of the individual or entity named above. If the reader of this message Is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly Prohibited. If you have received this transmission in error, please immediately reply to the sender that you have received this Communication in error and then delete it. Thank you. {0EXHIBIT Dwe sre----- Original Message ------ ~ Subject: Re: Baystar - 898 Sth Ave S From: Kyle McLaughlin Date: Tue, November 27, 2018 2:02 pm To: Meredith Peck Tam willing to do that, however J need this default dismissed and would need indemnification from any further claims from your client going forward —@ Vius-free. www.avast.com On Tue, Nov 27, 2018 at 1:59 PM Meredith Peck wrote: Kyle, Clarification - I meant to say that Danan is looking for you to indemnify and hold him harmless in regard to the outstanding rent owed to the landlord, 898 Fifth Avenue Holdings, and to satisfy any rent obligation. We sought the default to Protect Danan's interest, particularly because the landlord is seeking judgment against Danan. Thank you, Meredith A. Peck, Esq. Peck & Peck, P.A. 5200 Tamiami Trail North, Suite 101 Naples, Florida 34103 Telephone (239) 263-9811 Facsimile (239) 263-9818 For service of pleadings and court documents email: service@neckandpecklaw.com CONFIDENTIALITY NOTICE: The information contained in this transmission may be privileged and confidential, and ts intended only for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or please immediately reply to the sender that you have received this communication in error and then delete it. Thank you. z--eee-= Original Message -------- Subject: Re: Baystar - 898 Sth Ave S From: Kyle McLaughlin <, 7. > Date: Tue, November 27, 2018 1:32 pm To: Meredith Peck Meredith, Did you ever consider to ask me if I would be willing to do that instead of going through the trouble, wasted money and time to file for a default? Additionally as clarification, there is no rent owed to Baystar nor is Baystar seeking rent from Danan. Please advise IZ¢ “1g Virus-free. www.avast.com On Tue, Nov 27, 2018 at 12:49 PM Meredith Peck wrote: Kyle, As you know, I represent Danan and his interest. Danan is looking for you to indemnify and hold him harmtess in regard to the outstanding rent owed to Baystar and to satisfy any rent obligation. To protect my client's interest, we sought the default, particularly since Baystar is Sincerely, Meredith A. Peck, Esq. On Nov 27, 2018, at 11:42 AM, Kyle McLaughlin wrote: Meredith, A few things regarding this case that are extremely confusing. 1. T have been in constant communication with you in regards to what is going on with Hoffmann - your request for default came as an absolute shock to me as I have responded to all of your emails 2. What is Danan looking to accomplish by coming after me when this Is completely out of my control? is he wanting to be dismissed from hoffmann's suit? 3. As I mentioned before, Jack Newby, whom I am currently in another lawsuit with, was the basis for this entire problem and was the only signer on that NABOR agreement As Ive mentioned before, I am willing to cooperate with you and Danan, but my attempts so far have been unsuccessful with both him, and now you, Please advise Thanks, Kyle McLaughlin 239-641-1892 13