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  • Michael Knopf, Norma Knopf v. Frank M. Esposito, Dorsey & Whitney, Llp, Nathaniel H. Akerman, Edward S. Feldman Torts - Other (Fraud;Judiciary L. 487) document preview
  • Michael Knopf, Norma Knopf v. Frank M. Esposito, Dorsey & Whitney, Llp, Nathaniel H. Akerman, Edward S. Feldman Torts - Other (Fraud;Judiciary L. 487) document preview
  • Michael Knopf, Norma Knopf v. Frank M. Esposito, Dorsey & Whitney, Llp, Nathaniel H. Akerman, Edward S. Feldman Torts - Other (Fraud;Judiciary L. 487) document preview
  • Michael Knopf, Norma Knopf v. Frank M. Esposito, Dorsey & Whitney, Llp, Nathaniel H. Akerman, Edward S. Feldman Torts - Other (Fraud;Judiciary L. 487) document preview
						
                                

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FILED: NEW YORK COUNTY CLERK 06/01/2023 09:19 PM INDEX NO. 150315/2019 NYSCEF DOC. NO. 1101 RECEIVED NYSCEF: 06/01/2023 Exhibit 3 FILED: NEW YORK COUNTY CLERK 06/01/2023 09:19 PM INDEX NO. 150315/2019 NYSCEF DOC. NO. 1101 RECEIVED NYSCEF: 06/01/2023 ElWARD S.FELDMAN " NY, NJ a DC FELDMAN&ASSOCIATES,PLLC SETH L FELDMAN " NY, NJ a DC Attorneys at Law or coussa RACHEL IZOWER-FADDÉ "NY RICH†RD A. HOBSCEWAN & JOHN J.ROMAN-NY &NJ JOHN SONG YOOK HONG - NY March 14, 2016 EDws S. Emomm Eso. (2I2) 685-2277 ext. 15 efeldman@feldmanandassociates.com berrylawplic@gmail.com Eric W. Berry, Esq. Berry Law PLLC 8* 5 Columbus Circle, Floor New York, New York 10019 Re: Knopf v. Sanford, et al Dear Mr. Berry: Your email of March 10, 2016 has been received and reviewed. First, I do not accept nor respond well to threats, particularly those that are patently baseless. If this is your manner of practicing law, it is not mine. What follows is not a threat, but a sincere declaration of this firm's position. defendant" For you to "add my firm as a in your latest attack upon Mr. Sanford would be the height of a frivolous litigation and so blatantly in violation of the Rules of Professional Conduct and 22 NYCRR § 130-1.1 as to defy description. Whether I gave Mr. Sanford a legal opinion as to the efficacy of your claimed restraints and escrow order is a matter between myself and Mr. Sanford. If such an opinion was given and was wrong, that is a matter between Mr. Sanford and myself. If such an opinion was given and Mr. Sanford relied upon it to his detriment, that is for him to act upon - not your clients and certainly not you. Obviously at no time have I even met, much less represented your clients. There is absolutely no privity between them and me and my finn. The ONLY possible action against us would be a malpractice action for wrong advice. I assume that I need not go into the law on this - you are presumed to know it. However, rest assured that I shall if necessary. Your recent citation of Village Bd. of Village of Pleasantville v. Rattner, 130 A.D.2d 654, 655, 515 N.Y.S.3d (sic) 585, 586 (2d Dept. 1987) in your email of March 13, 2016 is in applicable. with is whether the information be released - it in no All it deals may way confers any liability upon the attorney. You are hereby put on notice that your threatened to be brought against myself and/or my firm has absolutely no basis in fact or law, as evidenced by the predicate paragraphs. To be clear and as you should be aware, Rule 3.1 states (a) a lawyer shall not bring a proceeding or assert an issue therein unless there is a basis in law and fact and (b) a lawyers conduct is NEW YORK OFFICE " 33 East 33rd Street, Suite 802 " New York, NY I0016-5364 · tel (2,12) 685-2277 " fax (212) 725-2798 NEW JERSBY OFFICE " 460 Bergen Boulevard " Palisades Park, NJ 07650 " tel (20I) 906-7877 · fax (212) 725-2798