Letter,Correspondence: Keesha Woods v. Musleh-Forest Realty, Llc, Mekkah Mediteranean Market, Dollar General Store

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                                150 Broadway ▪ New York ▪ New York       10038
                                                                         TEL. (212) 285-3800 ▪ www.subinlaw.com

                                                                                  May 19, 2022

                 Afshin Razi
                 6010 Bay Parkway Brooklyn NY
                 11204
                   Via Hand Delivery
                                                                                Keesha S. Woods v. Musleh-Forest Realty, LLC
                  Dr. Razi:

                         Please be advised that this office represents the above referenced plaintiff (“plaintiff”) for personal injuries sustained
                  as a result of defendants’ negligence.

                  PLEASE BE ADVISED YOU ARE HEREBY PUT ON NOTICE THAT YOU ARE REQUIRED TO SAVE AND
                  PRESERVE A COPY OF THE FOLLOWING DOCUMENTS:

                       1.  ALL HANDWRITTEN NOTES CREATED AT THE TIME OF YOUR MEDICAL EXAMINATION
                           OF PLAINTIFF.
                       2.  Any and all e-mails between yourself and any person, law firm, attorney, employee or agent of any law firm
                           or attorney, entity and/or representative of any entity, or anyone else relating to your Medical Examination
                           of plaintiff and/or plaintiff’s above referenced lawsuit;
                       3.  Any and all written correspondence (whether in writing, electronic, e-mail, fax, or text) between yourself and
                           any person, law firm, attorney, employee or agent of any law firm or attorney, entity and/or representative of
                           any entity, or anyone else relating to plaintiff and/or plaintiff’s above referenced lawsuit;
                       4.  All bills and/or invoices from you or your office relating to plaintiff; including but not limited  to; your
                           Medical Examination of plaintiff; your or any person on your behalf review of records; all consultations with
                           any person regarding plaintiff;
                       5.  Any and all documents created by you or on your behalf relating to your Medical Examination and review
                           of records of plaintiff;
                       6.  Any and all drafts of reports relating to your Medical Examination of plaintiff;
                       7.  Any and all addendums and/or drafts of addendums relating to your Independent Medical Examination of
                           plaintiff.

                           PLEASE     BE   FURTHER       ADVISED     THAT     YOUR     FAILURE      TO   PRESERVE      THE    ABOVE
                           DOCUMENTS AS REQUESTED WILL LEAD TO OUR CLAIM THAT YOU INTENTIONALLY
                           DESTROYED        EVIDENCE      AND   WE    WILL    PURSUE     APPROPRIATE        REMEDIES      THROUGH
                           JUDICIAL INTEREVENTION.

                        Thank you for your attention to this matter and for your anticipated cooperation.


                                                                                 Very truly yours,

                                                                                 s/ Herbert Subin, Esq.


                  cc: Via NYSCEF