On April 26, 2019 a
Exhibit,Appendix
was filed
involving a dispute between
Yangsil Kang Individually And As A Shareholder On Behalf Of Elim Home Care Agency, Llc And Evergreen Adult Daycare Center Inc.,
Yangsil Kang
Individually And As A Shareholder On Behalf Of Elim Home Care Agency, Llc And Evergreen Adult Daycare Center Inc.,
and
Byuyngi Koo A K A James Koo,
Byuyngi Koo
A K A James Koo,
Elim Home Care Agency, Llc,
Evergreen Adult Daycare Center Inc.,
Evergreen Adult Day Care In Flushing, Inc.,
Evergreen Adult Day Care In Ny, Inc.,
Evergreen Flushing New York Llc,
Evergreen Homecare Service Of Ny, Inc.,
Evergreen Senior Daycare Center Inc.,
Hyoungjong Koo A K A Tommy Koo,
Hyoungjong Koo
A K A Tommy Koo,
Sr Homecare Of Ny, Inc.,
for Commercial - Business Entity
in the District Court of Queens County.
Preview
FILED: QUEENS COUNTY CLERK 02/14/2023
07/31/2022 10:51
02:21 PM
AM INDEX NO. 707381/2019
NYSCEF DOC. NO. 127
94 RECEIVED NYSCEF: 02/14/2023
07/31/2022
Exhibit H
FILED: QUEENS COUNTY CLERK 02/14/2023
07/31/2022 10:51
02:21 PM
AM INDEX NO. 707381/2019
NYSCEF DOC. NO. 127
94 RECEIVED NYSCEF: 02/14/2023
07/31/2022
On Thu, Oct 21, 2021 at1:59 PM jinhan jinhanlaw.com wrote:
H1Andrew,
I want to clarify that my prmcipal objection to your document dump was not just to its size,
per se, but also to the apparent failure to categorize and label the mass of paperwork into separate
and cognizable files and sub files indicating to which of PlaintiEs Document Demands the
paperwork is responsive. This is required by CPLR 3122 (C).
I am not asking you to just cut the steak into bite-size pieces. I am asking you to categorize=
organize and label the paperwork by topic, subject matter and by the Demand as per all the
instructions in the Demand. Please let me know how long you will need to do this.
I had hoped for but do not require your consent to the tolling of my time to respond to your
discovery demands. The fact that your responses were due to be served well before mme shows
that a pnority was intended and it will not be subverted by delay tactics.
Best,
Jin
Jin Han, Esq.
Law Offices of Jin Han, P.C.
100 Park Avenue, Suite 1600
New York, N.Y. 10017
Tel (917) 7D1-7976 Fax (844) 840-8029
Email: jinhan@jinhanlaw.com Web: www.JinHanLaw.com
I A LAW OFFICES OF RN HAN, P.C.
Crimiml Law, Divorce, Medical Malpractice, Serious Personal Injury & Civil Litigation
This me ssage may contain confidential information that is protected by the ottorrrey-client privilege ar otherydse. (f you a.re not the
intended recipient, you are notified that any disclosure, ccpyin_q, or use of the contents of this message is strictly prohibited. ff this
message has been receind by you in error, please imtify the sender immediately by e-maid and delete the original message. Thank you.
Document Filed Date
February 14, 2023
Case Filing Date
April 26, 2019
Category
Commercial - Business Entity
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Preview
FILED: QUEENS COUNTY CLERK 02/14/2023 07/31/2022 10:51 02:21 PM AM INDEX NO. 707381/2019 NYSCEF DOC. NO. 127 94 RECEIVED NYSCEF: 02/14/2023 07/31/2022 Exhibit H FILED: QUEENS COUNTY CLERK 02/14/2023 07/31/2022 10:51 02:21 PM AM INDEX NO. 707381/2019 NYSCEF DOC. NO. 127 94 RECEIVED NYSCEF: 02/14/2023 07/31/2022 On Thu, Oct 21, 2021 at1:59 PM jinhan jinhanlaw.com wrote: H1Andrew, I want to clarify that my prmcipal objection to your document dump was not just to its size, per se, but also to the apparent failure to categorize and label the mass of paperwork into separate and cognizable files and sub files indicating to which of PlaintiEs Document Demands the paperwork is responsive. This is required by CPLR 3122 (C). I am not asking you to just cut the steak into bite-size pieces. I am asking you to categorize= organize and label the paperwork by topic, subject matter and by the Demand as per all the instructions in the Demand. Please let me know how long you will need to do this. I had hoped for but do not require your consent to the tolling of my time to respond to your discovery demands. The fact that your responses were due to be served well before mme shows that a pnority was intended and it will not be subverted by delay tactics. Best, Jin Jin Han, Esq. Law Offices of Jin Han, P.C. 100 Park Avenue, Suite 1600 New York, N.Y. 10017 Tel (917) 7D1-7976 Fax (844) 840-8029 Email: jinhan@jinhanlaw.com Web: www.JinHanLaw.com I A LAW OFFICES OF RN HAN, P.C. Crimiml Law, Divorce, Medical Malpractice, Serious Personal Injury & Civil Litigation This me ssage may contain confidential information that is protected by the ottorrrey-client privilege ar otherydse. (f you a.re not the intended recipient, you are notified that any disclosure, ccpyin_q, or use of the contents of this message is strictly prohibited. ff this message has been receind by you in error, please imtify the sender immediately by e-maid and delete the original message. Thank you.