Preview
FILED: HERKIMER COUNTY CLERK 04/28/2021 01:23 PM INDEX NO. EF2021-108166
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 04/28/2021
EXHIBIT D
FILED: HERKIMER COUNTY CLERK 04/28/2021 01:23 PM INDEX NO. EF2021-108166
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 04/28/2021
James Lapios
From: James Lagios
Sent: Thursday, April 15, 2021 7:45 AM
To: Pautz, Daniel
Subject: Re: [EXTERNAL] Ace of Diamonds
Categories: DM, #2257298 : 898019 : 1
Hi Dan,
I don'tthink they need to go to that trouble.
Ted ishappy to take care of it.
JPL
Sent from my iPhone
Please note to reduce the quantity of paper coming into our offices during the Coronavirus crisiswhen our staff is
working remotely, we request that allcommurications with this office should be through electronic means. Your
cooperation isappreciated.
lfRivKiyRAt(LER
James Lagios
Partner
66 South Pearl Street, 11th Fl.
Albany, NY 12207
D 518.641.7052 T 518.462.3000 F 518.462.4199
James.Lagios@rivkin.com
www.rivkinradler.com
alf in
Follow Rivkin Rounds for Health Law Undates
On Apr 15, 2021, at 7:37 AM, Pautz, Daniel wrote:
Thanks, Jim. Do you want my folks to take the signs down themselves? And document the condition to
make sure there isno allegation of malfeasance? Let me know.
Sent from my iPhone
On Apr 15, 2021, at 7:25 AM, James Lagios wrote:
1
FILED: HERKIMER COUNTY CLERK 04/28/2021 01:23 PM INDEX NO. EF2021-108166
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 04/28/2021
Good morning, Dan,
I spoke to my clients lastnight.
Ted Smith has a routine doctor appc,iritment today, and his daughter and her boyfriend,
who would otherwise be the two to step in and take care of this,are in Arizona right
now.
Also, appareritly, there isa significant storm expected to hit inthe next day or two, with
heavy rain and possible sleet expected.
Ted does have a handyman who can help in inthe absence of his daughter, but we
respectfully request until the end of the day this coming Monday to take care of it. They
will likelyget itdone at some point over the weekend.
In the meantime, just as a follow up to our lastdiscussion, by way of additional
background information, I didconfirm that Ted Smith has paid 100% the property taxes
on the parcels for the last 25 years or so.
clients'
I do look forward to reviewing your proposal when you are ready to share itin
the hopes that we can work something out.
Thanks.
JPL
Please note to reduce the quantity of paper coming into our offices during the
Coronavirus crisiswhen our staffisworking remotely, we request that all
communications with this office should be through slêctronic means. Your
cooperation isappreciated.
James Lagios
Partner
66 South Pearl Street, 11th Fl.
Albany, NY 12207
D 518.641.7052 T 518.462.3000 F 518.462.4199
James.Lagios@rivkin.com
www.rivkinradler.com
Follow Rivkin Rounds for Health Law Updates
From: Pautz, Daniel
Sent: Wednesday, April 14, 20214:37 PM
2
FILED: HERKIMER COUNTY CLERK 04/28/2021 01:23 PM INDEX NO. EF2021-108166
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 04/28/2021
To: James Lagios
Subject: RE: [EXTERNAL] Ace of Diamcads
Jim,
Client sent me a partition proposal. I am wórkiiig on making sense of it.In the
meantime, can you confirm signs willcome down by COB Friday? This seems very
important to them.
Thanks,
Dan
From: James Lagios
Sent: Tuesday, April 13, 20214:34 PM
To: Pautz, Daniel
Subject: Re: [EXTERNAL] Ace of Diamonds
External Email: Use caution before tiitking links or‡péhiús attachmé ,
Hi Dan,
Yes.
Injust wrapped up a depositica. Is therea number I should callyou on?
JPL
518.986.1990
Sent from my iPhone
Please note to reduce the quantity of paper coming into our offices during the
Coronavirus crisiswhen our staff isworking remotely, we request that all
cc==:±ations with this office should be through electronic means. Your
cooperation isappreciated.
JameS Lagios
Partner
66 South Pearl Street, 11th Fl.
Albany, NY 12207
D 518.641.7052 T 518.462.3000 F 518.462.4199
James.Lagios@rivkin.com
www.rivkinradler.com
Follow Rivkin Rounds for Health Law Updates
3
FILED: HERKIMER COUNTY CLERK 04/28/2021 01:23 PM INDEX NO. EF2021-108166
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 04/28/2021
On Apr 13, 2021, at 4:24 PM, Pautz, Daniel wrote:
Jim,
Any update on the signs? We reallyneed them down in the next day or
so. My clients are all over me about this.
Thanks,
Dan
Daniel J. Pautz,Esq.
Member
Litigation
315.218.8153 Direct
315.218.8451 Fax
dpautz@bsk.com
BONDiî#ENE9
One LincolnCenter, Syracuse,NY 13202-1355
This email is ONLYfor the person(s) named in the messageheader. Unlessotherwise indicated, it contains
information that is confidential, privileged or exempt from disclosure under applicable law. If you have
received it in error, please notify the sender of the error and delete the message.
NOTICE: This message may containinformation
thatis cGaf|dêñtial If you
or privilêged. are not the
intended
please
recipient, advisethe sender and delete
irññ7sdiatêiy this message.See:
http://www.rivkinradler.com/disclaimer-e!ectronic-communicatioj1s/ inferrñatisñ
for further on ccñfidsatia|ity.
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Preview
FILED: HERKIMER COUNTY CLERK 04/28/2021 01:23 PM INDEX NO. EF2021-108166 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 04/28/2021 EXHIBIT D FILED: HERKIMER COUNTY CLERK 04/28/2021 01:23 PM INDEX NO. EF2021-108166 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 04/28/2021 James Lapios From: James Lagios Sent: Thursday, April 15, 2021 7:45 AM To: Pautz, Daniel Subject: Re: [EXTERNAL] Ace of Diamonds Categories: DM, #2257298 : 898019 : 1 Hi Dan, I don'tthink they need to go to that trouble. Ted ishappy to take care of it. JPL Sent from my iPhone Please note to reduce the quantity of paper coming into our offices during the Coronavirus crisiswhen our staff is working remotely, we request that allcommurications with this office should be through electronic means. Your cooperation isappreciated. lfRivKiyRAt(LER James Lagios Partner 66 South Pearl Street, 11th Fl. Albany, NY 12207 D 518.641.7052 T 518.462.3000 F 518.462.4199 James.Lagios@rivkin.com www.rivkinradler.com alf in Follow Rivkin Rounds for Health Law Undates On Apr 15, 2021, at 7:37 AM, Pautz, Daniel wrote: Thanks, Jim. Do you want my folks to take the signs down themselves? And document the condition to make sure there isno allegation of malfeasance? Let me know. Sent from my iPhone On Apr 15, 2021, at 7:25 AM, James Lagios wrote: 1 FILED: HERKIMER COUNTY CLERK 04/28/2021 01:23 PM INDEX NO. EF2021-108166 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 04/28/2021 Good morning, Dan, I spoke to my clients lastnight. Ted Smith has a routine doctor appc,iritment today, and his daughter and her boyfriend, who would otherwise be the two to step in and take care of this,are in Arizona right now. Also, appareritly, there isa significant storm expected to hit inthe next day or two, with heavy rain and possible sleet expected. Ted does have a handyman who can help in inthe absence of his daughter, but we respectfully request until the end of the day this coming Monday to take care of it. They will likelyget itdone at some point over the weekend. In the meantime, just as a follow up to our lastdiscussion, by way of additional background information, I didconfirm that Ted Smith has paid 100% the property taxes on the parcels for the last 25 years or so. clients' I do look forward to reviewing your proposal when you are ready to share itin the hopes that we can work something out. Thanks. JPL Please note to reduce the quantity of paper coming into our offices during the Coronavirus crisiswhen our staffisworking remotely, we request that all communications with this office should be through slêctronic means. Your cooperation isappreciated. James Lagios Partner 66 South Pearl Street, 11th Fl. Albany, NY 12207 D 518.641.7052 T 518.462.3000 F 518.462.4199 James.Lagios@rivkin.com www.rivkinradler.com Follow Rivkin Rounds for Health Law Updates From: Pautz, Daniel Sent: Wednesday, April 14, 20214:37 PM 2 FILED: HERKIMER COUNTY CLERK 04/28/2021 01:23 PM INDEX NO. EF2021-108166 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 04/28/2021 To: James Lagios Subject: RE: [EXTERNAL] Ace of Diamcads Jim, Client sent me a partition proposal. I am wórkiiig on making sense of it.In the meantime, can you confirm signs willcome down by COB Friday? This seems very important to them. Thanks, Dan From: James Lagios Sent: Tuesday, April 13, 20214:34 PM To: Pautz, Daniel Subject: Re: [EXTERNAL] Ace of Diamonds External Email: Use caution before tiitking links or‡péhiús attachmé , Hi Dan, Yes. Injust wrapped up a depositica. Is therea number I should callyou on? JPL 518.986.1990 Sent from my iPhone Please note to reduce the quantity of paper coming into our offices during the Coronavirus crisiswhen our staff isworking remotely, we request that all cc==:±ations with this office should be through electronic means. Your cooperation isappreciated. JameS Lagios Partner 66 South Pearl Street, 11th Fl. Albany, NY 12207 D 518.641.7052 T 518.462.3000 F 518.462.4199 James.Lagios@rivkin.com www.rivkinradler.com Follow Rivkin Rounds for Health Law Updates 3 FILED: HERKIMER COUNTY CLERK 04/28/2021 01:23 PM INDEX NO. EF2021-108166 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 04/28/2021 On Apr 13, 2021, at 4:24 PM, Pautz, Daniel wrote: Jim, Any update on the signs? We reallyneed them down in the next day or so. My clients are all over me about this. Thanks, Dan Daniel J. Pautz,Esq. Member Litigation 315.218.8153 Direct 315.218.8451 Fax dpautz@bsk.com BONDiî#ENE9 One LincolnCenter, Syracuse,NY 13202-1355 This email is ONLYfor the person(s) named in the messageheader. Unlessotherwise indicated, it contains information that is confidential, privileged or exempt from disclosure under applicable law. If you have received it in error, please notify the sender of the error and delete the message. NOTICE: This message may containinformation thatis cGaf|dêñtial If you or privilêged. are not the intended please recipient, advisethe sender and delete irññ7sdiatêiy this message.See: http://www.rivkinradler.com/disclaimer-e!ectronic-communicatioj1s/ inferrñatisñ for further on ccñfidsatia|ity. 4