On May 11, 2018 a
Exhibit,Appendix
was filed
involving a dispute between
Zurich American Insurance Company,
and
First Specialty Insurance Corporation,
Western Beef Properties, Inc.,
Western Beef Retail, Inc.,
for Commercial - Insurance
in the District Court of New York County.
Preview
D: NEW YORK INDEX NO. 652336/2018
NYSCEF DOC. NO. 138 RECEIVED NYSCEF: 04/06/2021
RBrown@robertbrownlaw.com
From: RBrown@robertbrownlaw.com
Sent: Monday, December 04, 2017 3:55 PM
To: "Sandi Lohay’
Subject: RE: Desmond Garrett v Western Beef (Cactus Holdings); DOL 8/14/15 188238922
We are going to try our best to get an adjournment, but will be ready to go no matter what.
It would be nice to have some money to offer so we don’t look like idiots in front of the judge.
From: Sandi Lohay [mailto:Sandil@westernbeef.com]
Sent: Monday, December 04, 2017 3:52 PM
To: RBrown@robertbrownlaw.com
Subject: RE: Desmond Garrett v Western Beef (Cactus Holdings); DOL 8/14/15 188238922
On the phone with them now.
From: RBrown@robertbrownlaw.com [mailto:RBrown@robertbrownlaw.com]
Sent: Monday, December 04, 2017 3:47 PM
To: Sandi Lohay
Subject: RE: Desmond Garrett v Western Beef (Cactus Holdings); DOL 8/14/15 188238922
Tomorrow. No one has responded. We are sending an amended report adding the details of the last EBT
shortly.
From: Sandi Lohay [mailto:Sandil@westernbeef.com]
Sent: Monday, December 04, 2017 2:12 PM
To: RBrown@robertbrownlaw.com
Subject: RE: Desmond Garrett v Western Beef (Cactus Holdings); DOL 8/14/15 188238922
Hi Robert -
Has anyone gotten back to you in this? | have a call in to Abrams Fensterman. Waiting on them
to call me back.
Also, the 5° is tomorrow.
Does the trial start tomorrow or Wednesday?
Thanks,
Sandi
From: RBrown@robertbrownlaw.com [me
Sent: Sunday, December 03, 2017 8:17
To: Sandi Lohay; Dawn Addabbo; Dawn Addabbo (Cactus); ‘Anthony Genovesi'; ‘Frank V. Carone’
: RBrown@robertbrownlaw.com]
1
RB00503INDEX NO. 652336/2018
RECEIVED NYSCEF: 04/06/2021
lamonico@robertbrownlaw.com, Mary Filiberto@choosebroadspire.com;
NYSCEE CP Bind! Gall his n
blent@robertbrownlaw.com
Subject: Desmond Garrett v Western Beef (Cactus Holdings); DOL 8/14/15 188238922
Attached please find a revised pre-trial report on the above-referenced matter. | have also attached
photographs of the broken sidewalk. We believe that Plaintiff has a very strong liability case.
The case is marked final for trial on Wednesday, December 5". Let us know what, if any, authority we have to
settle.
Robert E. Brown, Esq.
Law Offices of Robert E. Brown, PC
44 Wall Street, 12th Floor
New York, NY 10005
(FINANCIAL DISTRICT OFFICE)
465 Belfield Avenue - Suite F
Staten Island, NY 10312
(ANNADALE OFFICE)
2409 Richmond Road
Staten Island, NY 10306
(NEW DORP OFFICE)
2 Mott Street, Suite 200
New York, NY 10013
(NEW CHINATOWN OFFICE)
Telephone numbers
Wall Street (212) 766-9779
Mott Street/Chinatown (347) 488-6969
Annadale, Staten Island (718) 979-9779
New Dorp, Staten Island — Foreclosure Deparment (718) 982-7010
Facsimile (718) 979-9784
www.RobertBrownLaw.com
RBO00504
Document Filed Date
April 06, 2021
Case Filing Date
May 11, 2018
Category
Commercial - Insurance
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
D: NEW YORK INDEX NO. 652336/2018 NYSCEF DOC. NO. 138 RECEIVED NYSCEF: 04/06/2021 RBrown@robertbrownlaw.com From: RBrown@robertbrownlaw.com Sent: Monday, December 04, 2017 3:55 PM To: "Sandi Lohay’ Subject: RE: Desmond Garrett v Western Beef (Cactus Holdings); DOL 8/14/15 188238922 We are going to try our best to get an adjournment, but will be ready to go no matter what. It would be nice to have some money to offer so we don’t look like idiots in front of the judge. From: Sandi Lohay [mailto:Sandil@westernbeef.com] Sent: Monday, December 04, 2017 3:52 PM To: RBrown@robertbrownlaw.com Subject: RE: Desmond Garrett v Western Beef (Cactus Holdings); DOL 8/14/15 188238922 On the phone with them now. From: RBrown@robertbrownlaw.com [mailto:RBrown@robertbrownlaw.com] Sent: Monday, December 04, 2017 3:47 PM To: Sandi Lohay Subject: RE: Desmond Garrett v Western Beef (Cactus Holdings); DOL 8/14/15 188238922 Tomorrow. No one has responded. We are sending an amended report adding the details of the last EBT shortly. From: Sandi Lohay [mailto:Sandil@westernbeef.com] Sent: Monday, December 04, 2017 2:12 PM To: RBrown@robertbrownlaw.com Subject: RE: Desmond Garrett v Western Beef (Cactus Holdings); DOL 8/14/15 188238922 Hi Robert - Has anyone gotten back to you in this? | have a call in to Abrams Fensterman. Waiting on them to call me back. Also, the 5° is tomorrow. Does the trial start tomorrow or Wednesday? Thanks, Sandi From: RBrown@robertbrownlaw.com [me Sent: Sunday, December 03, 2017 8:17 To: Sandi Lohay; Dawn Addabbo; Dawn Addabbo (Cactus); ‘Anthony Genovesi'; ‘Frank V. Carone’ : RBrown@robertbrownlaw.com] 1 RB00503INDEX NO. 652336/2018 RECEIVED NYSCEF: 04/06/2021 lamonico@robertbrownlaw.com, Mary Filiberto@choosebroadspire.com; NYSCEE CP Bind! Gall his n blent@robertbrownlaw.com Subject: Desmond Garrett v Western Beef (Cactus Holdings); DOL 8/14/15 188238922 Attached please find a revised pre-trial report on the above-referenced matter. | have also attached photographs of the broken sidewalk. We believe that Plaintiff has a very strong liability case. The case is marked final for trial on Wednesday, December 5". Let us know what, if any, authority we have to settle. Robert E. Brown, Esq. Law Offices of Robert E. Brown, PC 44 Wall Street, 12th Floor New York, NY 10005 (FINANCIAL DISTRICT OFFICE) 465 Belfield Avenue - Suite F Staten Island, NY 10312 (ANNADALE OFFICE) 2409 Richmond Road Staten Island, NY 10306 (NEW DORP OFFICE) 2 Mott Street, Suite 200 New York, NY 10013 (NEW CHINATOWN OFFICE) Telephone numbers Wall Street (212) 766-9779 Mott Street/Chinatown (347) 488-6969 Annadale, Staten Island (718) 979-9779 New Dorp, Staten Island — Foreclosure Deparment (718) 982-7010 Facsimile (718) 979-9784 www.RobertBrownLaw.com RBO00504