Exhibit,Appendix: Nicholas Grant v. 147-02/12 Liberty Ave., Llc., Jouvay Ny, Inc. D/B/A Jouvay Night Club, Isaac J. Rios, Professional Corporate Security Services, Inc., Isaac Rios Jr

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                                FILED:         KINGS       COUNTY         CLERK        12/29/2022             08:06       PM                        INDEX    NO.   510433/2019
   NYSCEF     DOC.   NO.   78                                                                                 RECEIVED      NYSCEF:     12/29/2022


         Matthew B. Stein

         From:                                 Matthew B. Stein
         Sent:                                 Thursday, September 15, 2022 3:02 PM
         To:                                   'Neil Palmieri'
         Cc:                                   bryan@brooklynjustice.com; RosAnn Piccolo; Nicole E. Forte; John Bieder
         Subject:                              RE: Nicholas Grant v. 147-02/12 Liberty Avenue, LLC et al - OBJECTION TO JOUVAY'S
                                               SUPPLEMENTAL DISCOVERY RESPONSES


         Thank you for your Email.     Please consider this Professional Service’s objection to Jouvay’s discovery response.          Please
         provide discovery responsive to items 5 and 6.       If you your client is not in possession or control of the requested
         documents, video and photographs then please respond accordingly.             Please consider this Professional Service’s demand
         for the deposition of Videsh Girisanker, or if no longer employed by Jouvay or under their control, the witness’s last
         known home address, telephone number and Email address.
         Thank you,
         Matt Stein




         Matthew (Matt) B. Stein, Esq.
         101 Greenwich Street, 20th floor
         New York, N.Y. 10006
         (212) 363-6900 Ex. 62
         Cell: (914) 621-2886
         mstein@gsbwlaw.com




         From: Neil Palmieri [mailto:neil.palmieri@bmmplaw.com]
         Sent: Thursday, September 15, 2022 2:20 PM
         To: Matthew B. Stein 
         Cc: bryan@brooklynjustice.com; RosAnn Piccolo ; Nicole E. Forte ;
         John Bieder 
         Subject: RE: Nicholas Grant v. 147-02/12 Liberty Avenue, LLC et al - SUPPLEMENTAL DISCOVERY RESPONSES

         CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the
         sender and know the content is safe.

         As you know, my firm represents Jouvay NY Inc d/b/a Jouvay Nightclub.

         Please accept this as our Supplemental Discovery Response relative to the June 16, 2022 discovery demand of
         Professional Security Services Corp.

         With respect to item number 5, we are following with the client two ascertain whether there is any type of list which
         would document all of the patrons who attended Jouvay Nightclub on the date of the incident. We note that the general
         manager of Jouvay, at the time of the incident was Videsh Girisanker.


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   FILED:         KINGS       COUNTY         CLERK        12/29/2022             08:06       PM                        INDEX    NO.   510433/2019
   NYSCEF     DOC.   NO.   78                                                                                 RECEIVED      NYSCEF:     12/29/2022
         With respect to item number 6, any video footage/ photographs in our possession will be forwarded under separate
         cover.

         This defendant reserves the right to amend and / or supplement the foregoing responses up to and including the time of
         trial.

         Please contact the undersigned with any questions.

         Sincerely,

         Neil J. Palmieri, Esq.
         Bongiorno, Montiglio, Mitchell & Palmieri, PLLC
         200 Old Country Road
         Suite 680
         Mineola, New York 11501
         516-620-0687 Direct
         516-972-0808 Cell
         516-742-1790 Fax
         Neil.Palmieri@bmmplaw.com
         www.bmmplaw.com




         Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s)
         and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is
         prohibited. If you are not the intended recipient, please contact the sender by reply e-mail, delete and then destroy all
         copies of the original message.

         From: Matthew B. Stein 
         Sent: Wednesday, September 14, 2022 5:44 PM
         To: Neil Palmieri 
         Cc: bryan@brooklynjustice.com; RosAnn Piccolo ; Ingrid Angulo ;
         Nicole E. Forte ; John Bieder ; William Mitchell
         
         Subject: Re: Nicholas Grant v. 147-02/12 Liberty Avenue, LLC et al - Plaintiff's deposition to be scheduled

         I am available tomorrow afternoon, but not Friday.

         Matt Stein


                  On Sep 14, 2022, at 4:26 PM, Neil Palmieri  wrote:


                  CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless
                  you recognize the sender and know the content is safe.

                  Counselors – let’s set up a virtual meeting (just the attorneys – no court involvement) for tomorrow or
                  this Friday. This way we can hammer out exactly what’s owed, etc. The new court rules essentially
                  require this type of self-directed, good faith effort in any event.
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