On September 07, 2018 a
Exhibit,Appendix
was filed
involving a dispute between
Brian C. Prusik,
and
Geddes Federal Savings And Loan Association,
Liberty Mutual Insurance Group Inc.,
for Commercial Division
in the District Court of Onondaga County.
Preview
FILED: ONONDAGA COUNTY CLERK 02/20/2019 02:45 PM INDEX NO. 008588/2018
NYSCEF DOC. NO. 50 RECEIVED NYSCEF: 02/20/2019
EXHIBIT D
FILED: ONONDAGA COUNTY CLERK 02/20/2019 02:45 PM INDEX NO. 008588/2018
NYSCEF DOC. NO. 50 RECEIVED NYSCEF: 02/20/2019
7oo Crossroads Building WOODS 19oo lvlain Place Tower
2 State Street, Ilochester, New York 14614
OVIATT Buffalo, New York 142o2
P 585987.2800 F 585.454.3968 GlLMAN P 716.248.3200 F 716.854.5100
LLP
Writer's Telephone Number: 585A45.2755
ATTORNEYS
Writer's Fax Number: 585.445.2655 .
woodsoman.com
Email: stephenburke@woodsoviatt.com
December 27, 2018
Kevin R. VanDuser, Esq.
Sugarman Law Firm LLP
211 W. Jefferson Street
Syracuse, New York 13202
Re: Prusik v. Liberty Mutual Insurance Group Inc., etc., et al.
Index No. E008588/2018
Dear Mr. VanDuser:
This letter serves as a good faith effort to resolve outstanding discovery issues in this matter.
Specifically, on or about December 3, 2018 we served Plaintiffs Omnibus Discovery Demands,
Plaintiffs First Interrogatories, and Plaintiffs First Demand for Production of Documents on
Defendant Liberty Mutual Insurance Group Inc. To date, Plaintiff has not received any responses to
the above demands and thus deems any objections to be waived. Please provide meaningful
responses to the above demands by Friday January 4, 2019.
Feel free to reach out to me if you would like to discuss.
Very truly yours,
WOODS OVIATT GILMAN LLP
Stephen P. Burke
Please direct responses to Rochester Office
SPB/mrm/red
cc: Brian Prusik (Sent Via Email)
people®
(6873094: } The art of representing
Document Filed Date
February 20, 2019
Case Filing Date
September 07, 2018
Category
Commercial Division
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FILED: ONONDAGA COUNTY CLERK 02/20/2019 02:45 PM INDEX NO. 008588/2018 NYSCEF DOC. NO. 50 RECEIVED NYSCEF: 02/20/2019 EXHIBIT D FILED: ONONDAGA COUNTY CLERK 02/20/2019 02:45 PM INDEX NO. 008588/2018 NYSCEF DOC. NO. 50 RECEIVED NYSCEF: 02/20/2019 7oo Crossroads Building WOODS 19oo lvlain Place Tower 2 State Street, Ilochester, New York 14614 OVIATT Buffalo, New York 142o2 P 585987.2800 F 585.454.3968 GlLMAN P 716.248.3200 F 716.854.5100 LLP Writer's Telephone Number: 585A45.2755 ATTORNEYS Writer's Fax Number: 585.445.2655 . woodsoman.com Email: stephenburke@woodsoviatt.com December 27, 2018 Kevin R. VanDuser, Esq. Sugarman Law Firm LLP 211 W. Jefferson Street Syracuse, New York 13202 Re: Prusik v. Liberty Mutual Insurance Group Inc., etc., et al. Index No. E008588/2018 Dear Mr. VanDuser: This letter serves as a good faith effort to resolve outstanding discovery issues in this matter. Specifically, on or about December 3, 2018 we served Plaintiffs Omnibus Discovery Demands, Plaintiffs First Interrogatories, and Plaintiffs First Demand for Production of Documents on Defendant Liberty Mutual Insurance Group Inc. To date, Plaintiff has not received any responses to the above demands and thus deems any objections to be waived. Please provide meaningful responses to the above demands by Friday January 4, 2019. Feel free to reach out to me if you would like to discuss. Very truly yours, WOODS OVIATT GILMAN LLP Stephen P. Burke Please direct responses to Rochester Office SPB/mrm/red cc: Brian Prusik (Sent Via Email) people® (6873094: } The art of representing