Exhibit,Appendix: Northern Murray Equity, Inc. v. Rocco Del Greco

On September 06, 2022 a Exhibit,Appendix was filed involving a dispute between Northern Murray Equity, Inc., and Rocco Del Greco, for Commercial - Contract in the District Court of New York County.

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FILED: NEW YORK COUNTY CLERK 12/01/2022 02:43 PM INDEX NO. 653237/2022
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 12/01/2022

EXHIBIT

C
FILED: NEW YORK COUNTY CLERK 12/01/2022 02:43 PM INDEX NO. 653237/2022
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 12/01/2022
From: rocco.delgreco@tnyg.com,
To: hrbatlaw@aol.com,
Cc: fchiang.0912@gmail.com, kschiang615@gmail.com,
Subject: Re:
Date: Fri,Nov 18,2022 10:13 pm

Everyone,

While I understand everyone's frustration, I do believe itis best-for everyone-to work together and move
forward in a positive way.

Restating my offer of full rent plus $900/mo for the remainder of the lease, allows for the best outcome for
everyone. Time itself could help resolve the challenges before us.

The pandemic has been hard on allof us, but we are the fortunate ones to be alive and well. Let's not lose sight
of that fact.

I hope you all have a Happy Thanksgiving with your loved ones.

Regards,

Rocco Del Greco
Chief Marketing Officer (CMO)
The New York Group

917.671.8834 Mobile
646.867.2520 Direct
rocco.delgreco@tnyg.com

Schedule a Zoom or Phone Call
https://calendly.com/roccodelgreco/call

LinkedIn
https://www.linkedin.com/in/roccodelgreco

The New York Group
Brand Engagement and Marketing Communications
https://www.tnyg.com

On Nov 18, 2022, at 4:14 PM, Howard R. Birnbach wrote:

A motion to enter judgment will be filedby the end of the month.

-----OriginalMessage-----
From: Rocco Del Greco
To: Florence Chiang
Cc: Howard R. Bimbach ; Kuo His Chiang
Sent: Fri,Nov 18, 2022 1:01 pm
Subject: Re:

Florence,
FILED: NEW YORK COUNTY CLERK 12/01/2022 02:43 PM INDEX NO. 653237/2022
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 12/01/2022
Yesterday evening 1 spoke to Imran Hossain, my attomey who was interacting with Howard, and I opened your UPS
package. I assumed you and your attorney would provide a surrender agreement for both of us to sign, since I had already
received your November statement via email.

While I do not believe 11/28 isachievable as a vacate date due to the Thanksgiving holiday weekend, I do see 11/30 as
doable if we come to an agreement.

Here is language sent to Ms. Ahn by Julia Currie, my former attorney back in theApril, which can be updated.

Tenant vacates the premises by April 30, 2022 and the parties execute a surrender agreement with a mutual release of
and
liability waiver of arrears.

Regards,

Rocco Del Greco
Chief Marketing Officer (CMO)
The New York Group

917.671.8834 Mobile
646.867.2520 Direct
rocco.delgreco@tnyg.com

Schedule a Call
https://roccodelgreco.com/schedule

LinkedIn
https://www.Iinkedin.com/in/roccodelgreco

The New York Group
Brand Engagement and Marketing Communications
https://www.tnyg.com

On Nov 18, 2022, at 10:21 AM, Florence Chiang wrote:

Rocco,

Please provide an update on vacating the premise by Monday November 28th.

Sent from my iPhone

On Nov 10, 2022, at 10:19 PM, Rocco Del Greco wrote:

Florence,

Received.

I'm waiting for a reply from my attorney, their firmis no longer participating in the VOLS program, but he said
he will get back to me about making an exception for a former client.I'll
letyou know as soon as I hear back.

Regards,

Rocco Del Greco
Chief Marketing Officer (CMO)
The New York Group

917.671.8834 Mobile
646.867.2520 Direct
rocco.delgreco@tnyg.com
FILED: NEW YORK COUNTY CLERK 12/01/2022 02:43 PM INDEX NO. 653237/2022
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 12/01/2022
Schedule a Zoom or Phone Call
https://calendly.com/roccodelgreco/call

LinkedIn
https://www.linkedin.com/in/roccodelgreco

The New York Group
Brand Engagement and Marketing Communications
https://www.tnyg.com

On Nov 10, 2022, at 9:34 PM, Florence Chiang wrote:

I've attached the rent demand for November 2022, which isto be sent via certified mail.

Mr. Birnbach, the forwarding address is:
110-21 73rd Road, Apt 2J
Forest HIIIs NY 11375

On Mon, Nov 7, 2022 at 9:13 PM Howard R. Bimbach wrote:
We willneed a forwarding address,

----Original Message-----
From: Rocco Del Greco
To: Howard R. Birnbach
Sent: Thu, Nov 3, 2022 4:40 pm
Subject: Re:

Howard,

I just
sent an email to Kuo and Florence to keep everyone on the same page.

Rocco Del Greco
IQQG9ditigr gg@gmail.com
917.671.8834 Mobile

Schedule a Zoom or Phone Call
httes://calendiv.com/roccodeloreco/call

LinkedIn
https://www.linkedin.com/in/roccodelareco

On Nov 1, 2022, at 5:03 PM, Howard R. Bimbach wrote:

Please tellFlorence that you consent to the listingand marketing of the unit and willbe leaving shortly.

-----Original Message-----
From: Rocco Del Greco
To: Howard R. Birnbach
Cc: f_ghjang,0912@amail.com
Sent: Tue, Nov 1, 2022 4:29 pm
Subject: Re:

Howard,

I want to cooperate with the landlord in every way, whether I stayor leave the space. This has been my
message to them over and over since before you were involved. But, without dialogue, everything get
FILED: NEW YORK COUNTY CLERK 12/01/2022 02:43 PM INDEX NO. 653237/2022
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 12/01/2022
stagnated. Thars why I wrote my letterto them on 10/5, which I assume you've already read. Ifnot,itis
attached. Thank you for reaching out to me.

Regards,

Rocco

On Oct 31, 2022, at 6:11 PM, Howard R. Bimbach wrote:

Willyou cooperate in the leasing of your premises?

Best,
Florence Chiang
phone: (516) 640-6113
email: fchiana.0912@.gmail.com

FILED: NEW YORK COUNTY CLERK 12/01/2022 02:43 PM INDEX NO. 653237/2022
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 12/01/2022
6:12 PM
10/31/22, https://mail.aol.com/webmail-std/en-us/PrintMessage

From: hrbatlaw@aol.com,
To: roccodelgreco@gmail.com, fchiang.0912@gmail.com,
Date: Mon, Oct 31, 2022 6:11 pm

Will you cooperate inthe leasing of your premises?

https://mail.aol.com/webmail-std/en-us/PrintMessage 1/1
FILED: NEW YORK COUNTY CLERK 12/01/2022 02:43 PM INDEX NO. 653237/2022
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 12/01/2022
10/31/22, 3:25 PM Re: Updatefrom Rocco

From: fchiang.0912@gmail.com,
To: roccodelgreco@gmail.com,
Cc: kschiang615@gmail.com, hrbatlaw@aol.com,
Subject: Re: Update from Rocco
Date: Mon, Oct 31, 2022 2:31 pm
Attachments: LettertoLandlord - October 5, 2022.docx (16K)
.. ..._.. __..._____... _
....................__...__.....___.._....____ _ ___.- .......
now."
I fmd itincredibly insulting that you are asking that "we work things out

What do you think we were doing before?

To be quite frank, I already think you have been disrespectful. This is what I calllip service. You don't have
$30,0007 Then what do you actually have? I don't care how much but at least show some seriousness as to what
you can pay. Yet you have done NOTHING. You have not made any genuine offer. In fact, you have made many
genuine offers but no follow through. All talk. No action.

Your empty prornises and our numerous attempts to provide you time to make payments are now no longer

being entertained.

I advise that you review your lease. Are you aware of the parameters for the predicament that you are in now?

Florence

On Oct 31, 2022, at 2:10 PM, Rocco Del Greco wrote:

Florence,

Two things to please keep in mind:

1. Idon't have 30K, which my attorney has been saying since the summer. Even ifI did, the tactics
of your current attorney lead me to #2:

2. Providing a down payment up front leaves me vulnerable for subsequent eviction, as mentioned
in my letter from 10/5 attached, to which a response was never received from you nor your
attorney.

payment"
"With threats of eviction, it would be foolish for me to provide any "down to
"
then subsequently be threatened again with eviction shortly thereafter.

My proposed repayment plan of arrears, as stated in my letter, leaves you as a landlord with
minimal disadvantage considering how the pandemic affected all of us.

On top of that, even ifwe don't reach agreement, 1 toldyour Mom in person and in my last email,
that we should work together n_o-w to find a new tenant while we wait for court proceedings. Most
people in this situation would not make such a genuine offer. I am trying to do everything I can to
work together, no matter the outcome.

I am frustrated with many things that have transpired since the beginning of the pandemic: the
significant loss of business, global supply shortages and a slower than anticipated economic

https://mail.aol.com/webmail-stdlen-us/PrintMessage 1/4
FILED: NEW YORK COUNTY CLERK 12/01/2022 02:43 PM INDEX NO. 653237/2022
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 12/01/2022
10/31/22, 3:25 PM Re: Update fromRocco

recovery. For a small business like mine, ithas been devastating! But, I have to stay motivated and
hopeful!

Lastly, I do not want my harshness of words to be conveyed as any disrespect, I want you and your

family to know how much I want to work this out so we can all be happy again.

Thanks for listening and Happy Halloween!!!

Rocco Del Greco
roccodelgreco(Ægmail.com
917.671.8834 Mobile

Schedule a Zoom or Phone Call
https://calendly.com/roccodelgreco/call

LinkedIn
https://www.linkedin.com/in/roccodelgreco

On Oct 29, 2022, at 3:02 PM, Florence wrote:
Chiang

Rocco,

Before we move forward, we firstwant a substantial amount of payment as was previously
discussed between our attorney and yours before he decided to no longer represent you.

We need $30,000 firstbefore we discuss or even consider your proposal

Florence

Sent from my iPhone

On Oct 26, 2022, at 8:47 PM, Florence wrote:
Chiang

Sent from my iPhone

Begin forwarded message:

From: Rocco Del Greco

Date: October 26, 2022 at 4:28:09 PM EDT
To: Kuo His Chiang , Florence Chiang

Subject: Re: Update from Rocco

Kuo and Florence,

https://mail.aol.com/webmail-std/en-us/PrintMessage 2/4
FILED: NEW YORK COUNTY CLERK 12/01/2022 02:43 PM INDEX NO. 653237/2022
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 12/01/2022
3:25 PM
10/31/22, Re: Update from Rocco

I am resending my email from a few weeks ago, as I am sure you will
appreciate my effortto stay connected.

Why are we not working together to either show the place to prospective
tenants or coming up with some agreement to move forward? Either of
these choices are in your best interest. As I said below, I am trying my best
to support you whether I stay in the space or not.

My pro bono attorney is no longer representing me because he claims that
he was getting nowhere with Howard and does not represent clients in

court, only with negotiations. Ithanked him for everything he has done, but
he is no longer involved. I am, however, open to having a callat anytime
with you and Howard.

Lastly, you may receive an insurance cancelation notice, please disregard

it,I have made the premium payment.

As always, I appreciate you giving the time and attention this matter
deserves.

Regards,

Rocco Del Greco
Chief Marketing Officer (CMO)
Chief Revenue Officer(CRO)
Executive Coach

917.671.8834 Mobile
roccodelgreco@gmail.com

Schedule a Call
https://roccodelgreco.com/schedule

LinkedIn
https://www.linkedin.com/in/roccodelgreco

About Me
https://roccodelgreco.com

On Oct 16, 2022, at 12:43 PM, Rocco Del Greco
wrote:

Kuo and Florence,

I heard back from my attorney that you rejected my proposal of full

monthly rent plus $900/month arrears. He feels,based on his experience,
that when the opposing attorney doesn't encourage an agreement or make a

counteroffer, that ittypically means the landlord doesn't want the tenant to
remain in the space. So he asked me to reach out to you personally to make
sure that this in fact is your position. If so, lets not continue waiting, lets
start showing the space to prospective tenants. If you want to reach an

https://mail.aol.com/webmail-std/en-us/PrintMessage 3/4
FILED: NEW YORK COUNTY CLERK 12/01/2022 02:43 PM INDEX NO. 653237/2022
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 12/01/2022
3:25 PM
10/31/22, Re: Update fromRocco

agreement with me, then we should talk. Either way, you have my full
support.

Regards,

Rocco Del Greco
Chief Marketing Otlicer (CMO)

917.671.8834 Mobile
roccodelgre_c_o@gmail.com

Schedule a Zoom or Phone Call
https://roccodelgreco/roccodelgreco/schedule

LinkedIn
https://www.1inkedin.com/in/roccodelgreco

About Me
https://roccodelgreco.com

https://mail.aol.com/webmail-std/en-us/PrintMessage 4/4
FILED: NEW YORK COUNTY CLERK 12/01/2022 02:43 PM INDEX NO. 653237/2022
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 12/01/2022

September 28, 2022

Kuo and Florence,

I am writing to you directly because itseems our attorneys are not able to come to a resolution

for several months now. Please read the following and know that I want to work this out with

your family. Itis very important to me.

Here are some things that have concerned me:

1. On May 27, 2022, Ms. Ahn agreed to accept the June and July rent at $3,274.91 per month. I

sent a bank check for the total amount.

Dear Julia,

My client agrees to your proposal. Please have bank checks made payable to the

landlord and delivered to my office, on or before June 1, 2022. Be advised that we will

be commencing a non-payment action, with the understanding that in the event we can

reach an agreement for your client's continued tenancy prior to July 31, 2022, we will

discontinue the action.

Yours truly,

Jenny C. Ahn

2. Ms. Ahn never replied my attorney's email sent on July 15, 2022.

Ms. Ahn,

Following up on my last email. Though my client has been made aware of section 55 in

his lease rider, and the accompanying limitations on subletting, he is again requesting
the landlord permit a subtenant as part of an agreement for payment of the arrears. This

is an important consideration for him maintaining the space for the remainder of his

lease term. Please advise and have a nice weekend.

Regards,
Julia Currie

3. On August 4, 2022, my attorney sent an email to Ms. Ahn about where to send the August

2022 payment and she never heard back.

Ms. Ahn,

Good morning. My client would like to know ifhe should send a bank check for the

August rent to you or directly to the landlord. He has also requested a response to my
email from July 15th, see below. Thank you.
FILED: NEW YORK COUNTY CLERK 12/01/2022 02:43 PM INDEX NO. 653237/2022
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 12/01/2022

Regards,
Julia Currie

payment"
With threats of eviction, itwould be foolish for me to provide any "down to then

subsequently be threatened again with eviction shortly thereafter. For our mutual interest and

protection, I respectfully offer the following:

1st
Starting October 1, 2022 I am prepared to send you two installment payments, on the and
15th
Of every month, for the remainder of my lease (approximately 68 months). With this plan,
you would receive the full monthly rent plus $900 each month for 68 months to payback

arrears. Here is an example:

October 2022
" $4,333.21 full rent
monthly
" $25 water

" $900 partial arrears
" 1st
$5,233.21TOTAL (paid in two $2,616.61installments on the and 15th)

I truly believe this is a fairagreement and will avoid any unnecessary stress.

My goal isto move forward with my business and to pay the arrears, minimizing your loss while

giving me time to recover from the economic downturn.

We have allsuffered enough throughout this pandemic. I hope you can understand how

important this isto me, and how much I want you to be happy. Thank you so much for your

consideration and willingness to listen.

Respectfully,

Rocco

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Exhibit,Appendix: Northern Murray Equity, Inc. v. Rocco Del Greco

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