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  • Shamar Anderson, Perpetual Appia, Melissa Akal, Ruthlyn Belnavis, Lieutenant Bollin, Donald Britton, Krystle Thompson as mother and natural guardian of J.B, Krystle Thompson as mother and natural guardian of K.B., Krystle Thompson Individually, Isaiah Boyd, Kenneth Brooks, John Burse, Shantele Coram-Burse as mother and natural guardian of S.B,, Shantele Coram-Burse as mother and natural guardian of J.B.,, Shantele Coram-Burse Individually, Monique Burton, Vicki Calhoun, Robert Cantine, Clarice Ingram, Jonique Chambers, Ronald Chambers as father and natural guardian of N.C., an infant,, Ronald Chambers as father and natural guardian of K.C., an infant,, Ronald Chambers Individually, Anthony Davis as father and natural guardian of A.D.,, Anthony Davis Individually, Michael Davis as legal guardian of S.D., an infant,, Michael Davis Individually, Anna Masopust, Michele Dixon Individually, Michele Dixon as mother and natural guardian of M.N.,, Aretha Donnelly, Renee Evans, Munesta Faulkner, Mark Frederick, Ideline Gomez, Isaac A. Gonzalez, Felicia Harris, Carol Holman, Kevin Ivey, Kebrah Ivey , as mother and natural guardian of K I.,, Kebrah Ivey as mother and natural guardian of K I.,, Kebrah Ivey as mother and natural guardian of K I.,, Kebrah Ivey as mother and natural guardian of K I.,, Kebrah Ivey Individually, Karissa James as mother and natural guardian of C.T., an infant,, Karissa James Individually, Cheryl Jett, Derek Johnson, Rhonda Johnson, Francesca Jones, Richard Jones, Rafael Jimenez as father and natural guardian M.J., an infant,, Rafael Jimenez Individually, Nadiyah Robinson Khalifah, Sally Leung, Dexter Lyons, Sonja Mckennie, Taylor Mckennie, Teresa Mckinnon, Stephanie Mendoza Individually, Stephanie Mendoza as mother and natural guardian of A.A.,, Stephanie Mendoza as mother and natural guardian of C.A, Danielle Mills, Jasmine Morris, Linda T. Murphy, Katherine Newby, Kelly O Gorman, Owen Ortiz as father and natural guardian of B.O.,, Owen Ortiz Individually, Tanya Richards as legal guardian of K.C., an infant, Tanya Richards Individually, Wendy Segura, Julian Jackson Radney , as father and natural guardian of N.R.,, Julian Jackson Radney Individually, Raphael Reyes, Prince Rivers, Rosa Ronca, Yuberki Silva Individually, Yuberki Silva as father and natural guardian of A.S., Melissa Smith, Robert Tapia, Joseph Willis, Joseph Willis Jr, Magdeline Wills, Shizuka Shearn, Edward Cole, Isatu Kabba, Miriam Kabba -individually and as mother and natural guardian of A A an infant, Joseph Zayas, Dorian Zayas -individually and as mother and natural guardian of J Z an infant, Akil Forest, Antoinette Silver -individually and as mother & natural guardian of A G an infant, David K Williams, Kathryn Williams, Lydia Koi v. Seven Pines Associates Limited Partnership, H & S Property Managment, Inc, Miama James, Premier Home Healthcare Services, Inc.,Torts - Other Negligence (Premises) document preview
  • Shamar Anderson, Perpetual Appia, Melissa Akal, Ruthlyn Belnavis, Lieutenant Bollin, Donald Britton, Krystle Thompson as mother and natural guardian of J.B, Krystle Thompson as mother and natural guardian of K.B., Krystle Thompson Individually, Isaiah Boyd, Kenneth Brooks, John Burse, Shantele Coram-Burse as mother and natural guardian of S.B,, Shantele Coram-Burse as mother and natural guardian of J.B.,, Shantele Coram-Burse Individually, Monique Burton, Vicki Calhoun, Robert Cantine, Clarice Ingram, Jonique Chambers, Ronald Chambers as father and natural guardian of N.C., an infant,, Ronald Chambers as father and natural guardian of K.C., an infant,, Ronald Chambers Individually, Anthony Davis as father and natural guardian of A.D.,, Anthony Davis Individually, Michael Davis as legal guardian of S.D., an infant,, Michael Davis Individually, Anna Masopust, Michele Dixon Individually, Michele Dixon as mother and natural guardian of M.N.,, Aretha Donnelly, Renee Evans, Munesta Faulkner, Mark Frederick, Ideline Gomez, Isaac A. Gonzalez, Felicia Harris, Carol Holman, Kevin Ivey, Kebrah Ivey , as mother and natural guardian of K I.,, Kebrah Ivey as mother and natural guardian of K I.,, Kebrah Ivey as mother and natural guardian of K I.,, Kebrah Ivey as mother and natural guardian of K I.,, Kebrah Ivey Individually, Karissa James as mother and natural guardian of C.T., an infant,, Karissa James Individually, Cheryl Jett, Derek Johnson, Rhonda Johnson, Francesca Jones, Richard Jones, Rafael Jimenez as father and natural guardian M.J., an infant,, Rafael Jimenez Individually, Nadiyah Robinson Khalifah, Sally Leung, Dexter Lyons, Sonja Mckennie, Taylor Mckennie, Teresa Mckinnon, Stephanie Mendoza Individually, Stephanie Mendoza as mother and natural guardian of A.A.,, Stephanie Mendoza as mother and natural guardian of C.A, Danielle Mills, Jasmine Morris, Linda T. Murphy, Katherine Newby, Kelly O Gorman, Owen Ortiz as father and natural guardian of B.O.,, Owen Ortiz Individually, Tanya Richards as legal guardian of K.C., an infant, Tanya Richards Individually, Wendy Segura, Julian Jackson Radney , as father and natural guardian of N.R.,, Julian Jackson Radney Individually, Raphael Reyes, Prince Rivers, Rosa Ronca, Yuberki Silva Individually, Yuberki Silva as father and natural guardian of A.S., Melissa Smith, Robert Tapia, Joseph Willis, Joseph Willis Jr, Magdeline Wills, Shizuka Shearn, Edward Cole, Isatu Kabba, Miriam Kabba -individually and as mother and natural guardian of A A an infant, Joseph Zayas, Dorian Zayas -individually and as mother and natural guardian of J Z an infant, Akil Forest, Antoinette Silver -individually and as mother & natural guardian of A G an infant, David K Williams, Kathryn Williams, Lydia Koi v. Seven Pines Associates Limited Partnership, H & S Property Managment, Inc, Miama James, Premier Home Healthcare Services, Inc.,Torts - Other Negligence (Premises) document preview
  • Shamar Anderson, Perpetual Appia, Melissa Akal, Ruthlyn Belnavis, Lieutenant Bollin, Donald Britton, Krystle Thompson as mother and natural guardian of J.B, Krystle Thompson as mother and natural guardian of K.B., Krystle Thompson Individually, Isaiah Boyd, Kenneth Brooks, John Burse, Shantele Coram-Burse as mother and natural guardian of S.B,, Shantele Coram-Burse as mother and natural guardian of J.B.,, Shantele Coram-Burse Individually, Monique Burton, Vicki Calhoun, Robert Cantine, Clarice Ingram, Jonique Chambers, Ronald Chambers as father and natural guardian of N.C., an infant,, Ronald Chambers as father and natural guardian of K.C., an infant,, Ronald Chambers Individually, Anthony Davis as father and natural guardian of A.D.,, Anthony Davis Individually, Michael Davis as legal guardian of S.D., an infant,, Michael Davis Individually, Anna Masopust, Michele Dixon Individually, Michele Dixon as mother and natural guardian of M.N.,, Aretha Donnelly, Renee Evans, Munesta Faulkner, Mark Frederick, Ideline Gomez, Isaac A. Gonzalez, Felicia Harris, Carol Holman, Kevin Ivey, Kebrah Ivey , as mother and natural guardian of K I.,, Kebrah Ivey as mother and natural guardian of K I.,, Kebrah Ivey as mother and natural guardian of K I.,, Kebrah Ivey as mother and natural guardian of K I.,, Kebrah Ivey Individually, Karissa James as mother and natural guardian of C.T., an infant,, Karissa James Individually, Cheryl Jett, Derek Johnson, Rhonda Johnson, Francesca Jones, Richard Jones, Rafael Jimenez as father and natural guardian M.J., an infant,, Rafael Jimenez Individually, Nadiyah Robinson Khalifah, Sally Leung, Dexter Lyons, Sonja Mckennie, Taylor Mckennie, Teresa Mckinnon, Stephanie Mendoza Individually, Stephanie Mendoza as mother and natural guardian of A.A.,, Stephanie Mendoza as mother and natural guardian of C.A, Danielle Mills, Jasmine Morris, Linda T. Murphy, Katherine Newby, Kelly O Gorman, Owen Ortiz as father and natural guardian of B.O.,, Owen Ortiz Individually, Tanya Richards as legal guardian of K.C., an infant, Tanya Richards Individually, Wendy Segura, Julian Jackson Radney , as father and natural guardian of N.R.,, Julian Jackson Radney Individually, Raphael Reyes, Prince Rivers, Rosa Ronca, Yuberki Silva Individually, Yuberki Silva as father and natural guardian of A.S., Melissa Smith, Robert Tapia, Joseph Willis, Joseph Willis Jr, Magdeline Wills, Shizuka Shearn, Edward Cole, Isatu Kabba, Miriam Kabba -individually and as mother and natural guardian of A A an infant, Joseph Zayas, Dorian Zayas -individually and as mother and natural guardian of J Z an infant, Akil Forest, Antoinette Silver -individually and as mother & natural guardian of A G an infant, David K Williams, Kathryn Williams, Lydia Koi v. Seven Pines Associates Limited Partnership, H & S Property Managment, Inc, Miama James, Premier Home Healthcare Services, Inc.,Torts - Other Negligence (Premises) document preview
  • Shamar Anderson, Perpetual Appia, Melissa Akal, Ruthlyn Belnavis, Lieutenant Bollin, Donald Britton, Krystle Thompson as mother and natural guardian of J.B, Krystle Thompson as mother and natural guardian of K.B., Krystle Thompson Individually, Isaiah Boyd, Kenneth Brooks, John Burse, Shantele Coram-Burse as mother and natural guardian of S.B,, Shantele Coram-Burse as mother and natural guardian of J.B.,, Shantele Coram-Burse Individually, Monique Burton, Vicki Calhoun, Robert Cantine, Clarice Ingram, Jonique Chambers, Ronald Chambers as father and natural guardian of N.C., an infant,, Ronald Chambers as father and natural guardian of K.C., an infant,, Ronald Chambers Individually, Anthony Davis as father and natural guardian of A.D.,, Anthony Davis Individually, Michael Davis as legal guardian of S.D., an infant,, Michael Davis Individually, Anna Masopust, Michele Dixon Individually, Michele Dixon as mother and natural guardian of M.N.,, Aretha Donnelly, Renee Evans, Munesta Faulkner, Mark Frederick, Ideline Gomez, Isaac A. Gonzalez, Felicia Harris, Carol Holman, Kevin Ivey, Kebrah Ivey , as mother and natural guardian of K I.,, Kebrah Ivey as mother and natural guardian of K I.,, Kebrah Ivey as mother and natural guardian of K I.,, Kebrah Ivey as mother and natural guardian of K I.,, Kebrah Ivey Individually, Karissa James as mother and natural guardian of C.T., an infant,, Karissa James Individually, Cheryl Jett, Derek Johnson, Rhonda Johnson, Francesca Jones, Richard Jones, Rafael Jimenez as father and natural guardian M.J., an infant,, Rafael Jimenez Individually, Nadiyah Robinson Khalifah, Sally Leung, Dexter Lyons, Sonja Mckennie, Taylor Mckennie, Teresa Mckinnon, Stephanie Mendoza Individually, Stephanie Mendoza as mother and natural guardian of A.A.,, Stephanie Mendoza as mother and natural guardian of C.A, Danielle Mills, Jasmine Morris, Linda T. Murphy, Katherine Newby, Kelly O Gorman, Owen Ortiz as father and natural guardian of B.O.,, Owen Ortiz Individually, Tanya Richards as legal guardian of K.C., an infant, Tanya Richards Individually, Wendy Segura, Julian Jackson Radney , as father and natural guardian of N.R.,, Julian Jackson Radney Individually, Raphael Reyes, Prince Rivers, Rosa Ronca, Yuberki Silva Individually, Yuberki Silva as father and natural guardian of A.S., Melissa Smith, Robert Tapia, Joseph Willis, Joseph Willis Jr, Magdeline Wills, Shizuka Shearn, Edward Cole, Isatu Kabba, Miriam Kabba -individually and as mother and natural guardian of A A an infant, Joseph Zayas, Dorian Zayas -individually and as mother and natural guardian of J Z an infant, Akil Forest, Antoinette Silver -individually and as mother & natural guardian of A G an infant, David K Williams, Kathryn Williams, Lydia Koi v. Seven Pines Associates Limited Partnership, H & S Property Managment, Inc, Miama James, Premier Home Healthcare Services, Inc.,Torts - Other Negligence (Premises) document preview
  • Shamar Anderson, Perpetual Appia, Melissa Akal, Ruthlyn Belnavis, Lieutenant Bollin, Donald Britton, Krystle Thompson as mother and natural guardian of J.B, Krystle Thompson as mother and natural guardian of K.B., Krystle Thompson Individually, Isaiah Boyd, Kenneth Brooks, John Burse, Shantele Coram-Burse as mother and natural guardian of S.B,, Shantele Coram-Burse as mother and natural guardian of J.B.,, Shantele Coram-Burse Individually, Monique Burton, Vicki Calhoun, Robert Cantine, Clarice Ingram, Jonique Chambers, Ronald Chambers as father and natural guardian of N.C., an infant,, Ronald Chambers as father and natural guardian of K.C., an infant,, Ronald Chambers Individually, Anthony Davis as father and natural guardian of A.D.,, Anthony Davis Individually, Michael Davis as legal guardian of S.D., an infant,, Michael Davis Individually, Anna Masopust, Michele Dixon Individually, Michele Dixon as mother and natural guardian of M.N.,, Aretha Donnelly, Renee Evans, Munesta Faulkner, Mark Frederick, Ideline Gomez, Isaac A. Gonzalez, Felicia Harris, Carol Holman, Kevin Ivey, Kebrah Ivey , as mother and natural guardian of K I.,, Kebrah Ivey as mother and natural guardian of K I.,, Kebrah Ivey as mother and natural guardian of K I.,, Kebrah Ivey as mother and natural guardian of K I.,, Kebrah Ivey Individually, Karissa James as mother and natural guardian of C.T., an infant,, Karissa James Individually, Cheryl Jett, Derek Johnson, Rhonda Johnson, Francesca Jones, Richard Jones, Rafael Jimenez as father and natural guardian M.J., an infant,, Rafael Jimenez Individually, Nadiyah Robinson Khalifah, Sally Leung, Dexter Lyons, Sonja Mckennie, Taylor Mckennie, Teresa Mckinnon, Stephanie Mendoza Individually, Stephanie Mendoza as mother and natural guardian of A.A.,, Stephanie Mendoza as mother and natural guardian of C.A, Danielle Mills, Jasmine Morris, Linda T. Murphy, Katherine Newby, Kelly O Gorman, Owen Ortiz as father and natural guardian of B.O.,, Owen Ortiz Individually, Tanya Richards as legal guardian of K.C., an infant, Tanya Richards Individually, Wendy Segura, Julian Jackson Radney , as father and natural guardian of N.R.,, Julian Jackson Radney Individually, Raphael Reyes, Prince Rivers, Rosa Ronca, Yuberki Silva Individually, Yuberki Silva as father and natural guardian of A.S., Melissa Smith, Robert Tapia, Joseph Willis, Joseph Willis Jr, Magdeline Wills, Shizuka Shearn, Edward Cole, Isatu Kabba, Miriam Kabba -individually and as mother and natural guardian of A A an infant, Joseph Zayas, Dorian Zayas -individually and as mother and natural guardian of J Z an infant, Akil Forest, Antoinette Silver -individually and as mother & natural guardian of A G an infant, David K Williams, Kathryn Williams, Lydia Koi v. Seven Pines Associates Limited Partnership, H & S Property Managment, Inc, Miama James, Premier Home Healthcare Services, Inc.,Torts - Other Negligence (Premises) document preview
  • Shamar Anderson, Perpetual Appia, Melissa Akal, Ruthlyn Belnavis, Lieutenant Bollin, Donald Britton, Krystle Thompson as mother and natural guardian of J.B, Krystle Thompson as mother and natural guardian of K.B., Krystle Thompson Individually, Isaiah Boyd, Kenneth Brooks, John Burse, Shantele Coram-Burse as mother and natural guardian of S.B,, Shantele Coram-Burse as mother and natural guardian of J.B.,, Shantele Coram-Burse Individually, Monique Burton, Vicki Calhoun, Robert Cantine, Clarice Ingram, Jonique Chambers, Ronald Chambers as father and natural guardian of N.C., an infant,, Ronald Chambers as father and natural guardian of K.C., an infant,, Ronald Chambers Individually, Anthony Davis as father and natural guardian of A.D.,, Anthony Davis Individually, Michael Davis as legal guardian of S.D., an infant,, Michael Davis Individually, Anna Masopust, Michele Dixon Individually, Michele Dixon as mother and natural guardian of M.N.,, Aretha Donnelly, Renee Evans, Munesta Faulkner, Mark Frederick, Ideline Gomez, Isaac A. Gonzalez, Felicia Harris, Carol Holman, Kevin Ivey, Kebrah Ivey , as mother and natural guardian of K I.,, Kebrah Ivey as mother and natural guardian of K I.,, Kebrah Ivey as mother and natural guardian of K I.,, Kebrah Ivey as mother and natural guardian of K I.,, Kebrah Ivey Individually, Karissa James as mother and natural guardian of C.T., an infant,, Karissa James Individually, Cheryl Jett, Derek Johnson, Rhonda Johnson, Francesca Jones, Richard Jones, Rafael Jimenez as father and natural guardian M.J., an infant,, Rafael Jimenez Individually, Nadiyah Robinson Khalifah, Sally Leung, Dexter Lyons, Sonja Mckennie, Taylor Mckennie, Teresa Mckinnon, Stephanie Mendoza Individually, Stephanie Mendoza as mother and natural guardian of A.A.,, Stephanie Mendoza as mother and natural guardian of C.A, Danielle Mills, Jasmine Morris, Linda T. Murphy, Katherine Newby, Kelly O Gorman, Owen Ortiz as father and natural guardian of B.O.,, Owen Ortiz Individually, Tanya Richards as legal guardian of K.C., an infant, Tanya Richards Individually, Wendy Segura, Julian Jackson Radney , as father and natural guardian of N.R.,, Julian Jackson Radney Individually, Raphael Reyes, Prince Rivers, Rosa Ronca, Yuberki Silva Individually, Yuberki Silva as father and natural guardian of A.S., Melissa Smith, Robert Tapia, Joseph Willis, Joseph Willis Jr, Magdeline Wills, Shizuka Shearn, Edward Cole, Isatu Kabba, Miriam Kabba -individually and as mother and natural guardian of A A an infant, Joseph Zayas, Dorian Zayas -individually and as mother and natural guardian of J Z an infant, Akil Forest, Antoinette Silver -individually and as mother & natural guardian of A G an infant, David K Williams, Kathryn Williams, Lydia Koi v. Seven Pines Associates Limited Partnership, H & S Property Managment, Inc, Miama James, Premier Home Healthcare Services, Inc.,Torts - Other Negligence (Premises) document preview
  • Shamar Anderson, Perpetual Appia, Melissa Akal, Ruthlyn Belnavis, Lieutenant Bollin, Donald Britton, Krystle Thompson as mother and natural guardian of J.B, Krystle Thompson as mother and natural guardian of K.B., Krystle Thompson Individually, Isaiah Boyd, Kenneth Brooks, John Burse, Shantele Coram-Burse as mother and natural guardian of S.B,, Shantele Coram-Burse as mother and natural guardian of J.B.,, Shantele Coram-Burse Individually, Monique Burton, Vicki Calhoun, Robert Cantine, Clarice Ingram, Jonique Chambers, Ronald Chambers as father and natural guardian of N.C., an infant,, Ronald Chambers as father and natural guardian of K.C., an infant,, Ronald Chambers Individually, Anthony Davis as father and natural guardian of A.D.,, Anthony Davis Individually, Michael Davis as legal guardian of S.D., an infant,, Michael Davis Individually, Anna Masopust, Michele Dixon Individually, Michele Dixon as mother and natural guardian of M.N.,, Aretha Donnelly, Renee Evans, Munesta Faulkner, Mark Frederick, Ideline Gomez, Isaac A. Gonzalez, Felicia Harris, Carol Holman, Kevin Ivey, Kebrah Ivey , as mother and natural guardian of K I.,, Kebrah Ivey as mother and natural guardian of K I.,, Kebrah Ivey as mother and natural guardian of K I.,, Kebrah Ivey as mother and natural guardian of K I.,, Kebrah Ivey Individually, Karissa James as mother and natural guardian of C.T., an infant,, Karissa James Individually, Cheryl Jett, Derek Johnson, Rhonda Johnson, Francesca Jones, Richard Jones, Rafael Jimenez as father and natural guardian M.J., an infant,, Rafael Jimenez Individually, Nadiyah Robinson Khalifah, Sally Leung, Dexter Lyons, Sonja Mckennie, Taylor Mckennie, Teresa Mckinnon, Stephanie Mendoza Individually, Stephanie Mendoza as mother and natural guardian of A.A.,, Stephanie Mendoza as mother and natural guardian of C.A, Danielle Mills, Jasmine Morris, Linda T. Murphy, Katherine Newby, Kelly O Gorman, Owen Ortiz as father and natural guardian of B.O.,, Owen Ortiz Individually, Tanya Richards as legal guardian of K.C., an infant, Tanya Richards Individually, Wendy Segura, Julian Jackson Radney , as father and natural guardian of N.R.,, Julian Jackson Radney Individually, Raphael Reyes, Prince Rivers, Rosa Ronca, Yuberki Silva Individually, Yuberki Silva as father and natural guardian of A.S., Melissa Smith, Robert Tapia, Joseph Willis, Joseph Willis Jr, Magdeline Wills, Shizuka Shearn, Edward Cole, Isatu Kabba, Miriam Kabba -individually and as mother and natural guardian of A A an infant, Joseph Zayas, Dorian Zayas -individually and as mother and natural guardian of J Z an infant, Akil Forest, Antoinette Silver -individually and as mother & natural guardian of A G an infant, David K Williams, Kathryn Williams, Lydia Koi v. Seven Pines Associates Limited Partnership, H & S Property Managment, Inc, Miama James, Premier Home Healthcare Services, Inc.,Torts - Other Negligence (Premises) document preview
  • Shamar Anderson, Perpetual Appia, Melissa Akal, Ruthlyn Belnavis, Lieutenant Bollin, Donald Britton, Krystle Thompson as mother and natural guardian of J.B, Krystle Thompson as mother and natural guardian of K.B., Krystle Thompson Individually, Isaiah Boyd, Kenneth Brooks, John Burse, Shantele Coram-Burse as mother and natural guardian of S.B,, Shantele Coram-Burse as mother and natural guardian of J.B.,, Shantele Coram-Burse Individually, Monique Burton, Vicki Calhoun, Robert Cantine, Clarice Ingram, Jonique Chambers, Ronald Chambers as father and natural guardian of N.C., an infant,, Ronald Chambers as father and natural guardian of K.C., an infant,, Ronald Chambers Individually, Anthony Davis as father and natural guardian of A.D.,, Anthony Davis Individually, Michael Davis as legal guardian of S.D., an infant,, Michael Davis Individually, Anna Masopust, Michele Dixon Individually, Michele Dixon as mother and natural guardian of M.N.,, Aretha Donnelly, Renee Evans, Munesta Faulkner, Mark Frederick, Ideline Gomez, Isaac A. Gonzalez, Felicia Harris, Carol Holman, Kevin Ivey, Kebrah Ivey , as mother and natural guardian of K I.,, Kebrah Ivey as mother and natural guardian of K I.,, Kebrah Ivey as mother and natural guardian of K I.,, Kebrah Ivey as mother and natural guardian of K I.,, Kebrah Ivey Individually, Karissa James as mother and natural guardian of C.T., an infant,, Karissa James Individually, Cheryl Jett, Derek Johnson, Rhonda Johnson, Francesca Jones, Richard Jones, Rafael Jimenez as father and natural guardian M.J., an infant,, Rafael Jimenez Individually, Nadiyah Robinson Khalifah, Sally Leung, Dexter Lyons, Sonja Mckennie, Taylor Mckennie, Teresa Mckinnon, Stephanie Mendoza Individually, Stephanie Mendoza as mother and natural guardian of A.A.,, Stephanie Mendoza as mother and natural guardian of C.A, Danielle Mills, Jasmine Morris, Linda T. Murphy, Katherine Newby, Kelly O Gorman, Owen Ortiz as father and natural guardian of B.O.,, Owen Ortiz Individually, Tanya Richards as legal guardian of K.C., an infant, Tanya Richards Individually, Wendy Segura, Julian Jackson Radney , as father and natural guardian of N.R.,, Julian Jackson Radney Individually, Raphael Reyes, Prince Rivers, Rosa Ronca, Yuberki Silva Individually, Yuberki Silva as father and natural guardian of A.S., Melissa Smith, Robert Tapia, Joseph Willis, Joseph Willis Jr, Magdeline Wills, Shizuka Shearn, Edward Cole, Isatu Kabba, Miriam Kabba -individually and as mother and natural guardian of A A an infant, Joseph Zayas, Dorian Zayas -individually and as mother and natural guardian of J Z an infant, Akil Forest, Antoinette Silver -individually and as mother & natural guardian of A G an infant, David K Williams, Kathryn Williams, Lydia Koi v. Seven Pines Associates Limited Partnership, H & S Property Managment, Inc, Miama James, Premier Home Healthcare Services, Inc.,Torts - Other Negligence (Premises) document preview 
						
                                
Preview

                                FILED: WESTCHESTER COUNTY CLERK 07/18/2023 04:15 PM                                                     INDEX NO. 64252/2021
NYSCEF DOC. NO. 69                                                                            RECEIVED NYSCEF: 07/18/2023


    Christine Diaz

    From:                            Arlene Ilg
    Sent:                            July 14, 2023 1:44 PM
    To:                              'jrisi@pmtlawfirm.com'
    Cc:                              Robert Vilensky; Christine Diaz; Nadia Lescott; Howard Carrasquillo; AdamBernstein
                                     (AdamBernstein@brkblaw.com); 'JMaxwell@cozen.com'
    Subject:                         Regarding: Anderson, Shamar, et al v. Seven Pine Associates Limited Partnership, et al.


    Dear John,
    I am wri ng to let you know that on Monday I will have no alterna ve but to file a mo on to strike due to outstanding
    discovery.
    Please forward outstanding discovery to our office so that mo on prac ce can be avoided.
    Thank you and have a nice weekend.
    Regards,

    Arlene Ilg
    Ronemus & Vilensky
    112 Madison Avenue
    New York, NY 10016
    Tel - 212-779-7070
    Cell – 631-205-8069
    Fax - 212-686-2490
    arlene.ilg@ronvil.com




                                                               1
FILED: WESTCHESTER COUNTY CLERK 07/18/2023 04:15 PM                                                           INDEX NO. 64252/2021
NYSCEF DOC. NO. 69                                                                                  RECEIVED NYSCEF: 07/18/2023


    Christine Diaz

    From:                                    John A. Risi 
    Sent:                                    June 14, 2023 12:08 PM
    To:                                      Robert Vilensky
    Cc:                                      Arlene Ilg
    Subject:                                 RE: Anderson- Forrest v. Seven Pines/Anderson et al. v. Seven Pines Assoc. Limited
                                             partnership // Cozen File No.: 00534381


    I believe so, just trying to get it.

    From: Robert Vilensky 
    Sent: Wednesday, June 14, 2023 11:05 AM
    To: John A. Risi 
    Cc: Arlene Ilg 
    Subject: Re: Anderson- Forrest v. Seven Pines/Anderson et al. v. Seven Pines Assoc. Limited partnership // Cozen File
    No.: 00534381


    CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking
    links, especially from unknown senders.

    Is there excess?
    Thx

    Sent from my iPhone


             On Jun 14, 2023, at 10:43 AM, John A. Risi  wrote:


             Arlene,

             Here is the primary policy.

             Thank you,
             John

             John A. Risi
             Partner
             Pillinger Miller Tarallo, LLP
             jrisi@pmtlawfirm.com

             555 Taxter Road, 5th Floor, Elmsford, New York 10523
             T: 914.703.6300 x1209 | D: 914.829.5904
             F: 914.703.6688

             33 Oakwood Avenue, Norwalk, Connecticut 06850
             T: (203) 836-2307 | F: (203) 836-2308

             www.pmtlawfirm.com



                                                                      1
FILED: WESTCHESTER COUNTY CLERK 07/18/2023 04:15 PM                                                    INDEX NO. 64252/2021
NYSCEF DOC. NO. 69                                                                            RECEIVED NYSCEF: 07/18/2023
          
          New York - New Jersey - Pennsylvania - Connecticut
          Please Note: The information contained in this email message is information protected by attorney-
          client and/or the attorney work product privilege. It is intended only for the use of the individual
          named above and the privileges are not waived by virtue of this communication having been sent by
          email. If the person receiving this communication or any other reader of the communication is not the
          named recipient or the employee or agent responsible to deliver it to the named recipient, any use,
          dissemination, distribution or copying of the communication is strictly prohibited. If you have
          received this communication in error, please immediately notify us by the telephone number
          above. Thank you for your cooperation.




          From: John A. Risi
          Sent: Wednesday, June 14, 2023 10:26 AM
          To: 'Arlene Ilg' 
          Cc: Robert Vilensky 
          Subject: RE: Anderson- Forrest v. Seven Pines/Anderson et al. v. Seven Pines Assoc. Limited partnership
          // Cozen File No.: 00534381

          Ok I will send the primary informally over e-mail for expedience and will get you the excess as soon as I
          have it.

          From: Arlene Ilg 
          Sent: Wednesday, June 14, 2023 9:55 AM
          To: John A. Risi 
          Cc: Robert Vilensky 
          Subject: RE: Anderson- Forrest v. Seven Pines/Anderson et al. v. Seven Pines Assoc. Limited partnership
          // Cozen File No.: 00534381


          CAUTION: This email originated from outside your organization. Exercise caution when opening
          attachments or clicking links, especially from unknown senders.

          Hi John,
          Please send the insurance information asap. The rest can follow when you get it although I need that
          sooner rather than later as well.

          Thanks,
          Arlene



          From: John A. Risi 
          Sent: Wednesday, June 14, 2023 9:07 AM
          To: Arlene Ilg 
          Subject: RE: Anderson- Forrest v. Seven Pines/Anderson et al. v. Seven Pines Assoc. Limited partnership
          // Cozen File No.: 00534381

          Not at all Arlene, I am working with the clients to provide responses, but I will get you as many
          responses that don’t require docs as soon as possible.

          From: Arlene Ilg 
          Sent: Tuesday, June 13, 2023 1:48 PM
          To: John A. Risi ; Auden Robertson ; Robert
                                                               2
FILED: WESTCHESTER COUNTY CLERK 07/18/2023 04:15 PM                                                       INDEX NO. 64252/2021
NYSCEF DOC. NO. 69                                                                              RECEIVED NYSCEF: 07/18/2023
          Vilensky ; Christine Diaz ; Nadia Lescott
          ; JMaxwell@cozen.com
          Cc: SPanoyan@cozen.com; Erica Podolsky ; Howard Carrasquillo
          ; Larry Singer ; Nadia Lescott
          
          Subject: RE: Anderson- Forrest v. Seven Pines/Anderson et al. v. Seven Pines Assoc. Limited partnership
          // Cozen File No.: 00534381


          CAUTION: This email originated from outside your organization. Exercise caution when opening
          attachments or clicking links, especially from unknown senders.

          Hi John,
          I realize this email may be a little off topic but I was hoping to have a response to our good faith letter of
          6/1/23 by now. I just left you a voicemail. Please call me directly at 631-205-8069 to discuss further.
          Thank you,
          Arlene

          Arlene Ilg
          Ronemus & Vilensky
          112 Madison Avenue
          New York, NY 10016
          Tel - 212-779-7070
          Cell – 631-205-8069
          Fax - 212-686-2490
          arlene.ilg@ronvil.com



          From: John A. Risi 
          Sent: Tuesday, June 13, 2023 12:48 PM
          To: Auden Robertson ; Robert Vilensky ; Christine
          Diaz ; Nadia Lescott ; JMaxwell@cozen.com
          Cc: SPanoyan@cozen.com; Erica Podolsky ; Arlene Ilg
          ; Howard Carrasquillo ; Larry Singer
          ; Nadia Lescott 
          Subject: RE: Anderson- Forrest v. Seven Pines/Anderson et al. v. Seven Pines Assoc. Limited partnership
          // Cozen File No.: 00534381

          I don’t want to make any assumptions, but will an interpreter be needed and what time was everyone
          looking to start the deposition?

          Thank you,
          John

          John A. Risi
          Partner
          Pillinger Miller Tarallo, LLP
          jrisi@pmtlawfirm.com

          555 Taxter Road, 5th Floor, Elmsford, New York 10523
          T: 914.703.6300 x1209 | D: 914.829.5904
          F: 914.703.6688

                                                                 3
FILED: WESTCHESTER COUNTY CLERK 07/18/2023 04:15 PM                                                  INDEX NO. 64252/2021
NYSCEF DOC. NO. 69                                                                         RECEIVED NYSCEF: 07/18/2023
          33 Oakwood Avenue, Norwalk, Connecticut 06850
          T: (203) 836-2307 | F: (203) 836-2308

          www.pmtlawfirm.com


          
          New York - New Jersey - Pennsylvania - Connecticut
          Please Note: The information contained in this email message is information protected by attorney-
          client and/or the attorney work product privilege. It is intended only for the use of the individual
          named above and the privileges are not waived by virtue of this communication having been sent by
          email. If the person receiving this communication or any other reader of the communication is not the
          named recipient or the employee or agent responsible to deliver it to the named recipient, any use,
          dissemination, distribution or copying of the communication is strictly prohibited. If you have
          received this communication in error, please immediately notify us by the telephone number
          above. Thank you for your cooperation.




          From: Auden Robertson 
          Sent: Tuesday, June 13, 2023 12:46 PM
          To: Robert Vilensky ; Christine Diaz ; Nadia Lescott
          ; JMaxwell@cozen.com
          Cc: SPanoyan@cozen.com; John A. Risi ; Erica Podolsky
          ; Arlene Ilg ; Howard Carrasquillo
          ; Larry Singer ; Nadia Lescott
          
          Subject: RE: Anderson- Forrest v. Seven Pines/Anderson et al. v. Seven Pines Assoc. Limited partnership
          // Cozen File No.: 00534381


          CAUTION: This email originated from outside your organization. Exercise caution when opening
          attachments or clicking links, especially from unknown senders.

          Good afternoon Joel,

          The deposition is on Thursday, 6-15-23 not Friday.

          Best regards,

          Auden Robertson
          Calendar Clerk
          Ronemus & Vilensky LLP
          112 Madison Ave, 2nd Floor
          New York, NY 10016
          Email: AudenRobertson@Ronvil.com
          Phone: (212)779-7070 ext. 214
          Fax: (212)686-2490


          CONFIDENTIALITY NOTE: This E-mail is intended only for the person or entity
          to which it is addressed and may contain information that is privileged,
          confidential or otherwise protected from disclosure. Dissemination,
          distribution, or copying of this E-mail or the information herein by anyone
                                                             4
FILED: WESTCHESTER COUNTY CLERK 07/18/2023 04:15 PM                                                                                                                                                          INDEX NO. 64252/2021
NYSCEF DOC. NO. 69                                                                                                                                                                                    RECEIVED NYSCEF: 07/18/2023

          other than the intended recipient, is prohibited. If you have received this E-
          mail in error, please notify sender immediately by telephone at (212) 779-7070




          From: Robert Vilensky 
          Sent: Tuesday, June 13, 2023 12:25 PM
          To: Auden Robertson ; Christine Diaz ;
          Nadia Lescott 
          Subject: FW: Anderson- Forrest v. Seven Pines/Anderson et al. v. Seven Pines Assoc. Limited partnership
          // Cozen File No.: 00534381


          See below
          From: Maxwell, Joel M. 
          Sent: Tuesday, June 13, 2023 12:19 PM
          To: Erica Podolsky ; 'John A. Risi' ; Panoyan, Susan
          E. 
          Cc: Arlene Ilg ; Cindy Perez ; Howard Carrasquillo
          ; Robert Vilensky 
          Subject: RE: Anderson- Forrest v. Seven Pines/Anderson et al. v. Seven Pines Assoc. Limited partnership
          // Cozen File No.: 00534381

          Hi All,

          I know I am a day early, but I am just wondering if we are looking like we are on track for the deposition
          on Friday. If so, I think John’s office orders.

          Thanks!

          Joel

                                                                                                                                        Joel M. Maxwell
                 To help protect y ou r priv acy , Microsoft O ffice prev ented automatic download of this picture from the Internet.   Member | Cozen O'Connor
                                                                                                                                        3 WTC, 175 Greenwich Street 55th Floor | New York, NY 10007
                                                                                                                                        P: 212-908-1359 F: 646-225-5109 C: 516-639-4564
                                                                                                                                        Email | Map | cozen.com




          From: Maxwell, Joel M.
          Sent: Friday, June 2, 2023 10:49 AM
          To: 'Erica Podolsky' ; 'John A. Risi' ; Panoyan, Susan
          E. 
          Cc: Arlene Ilg ; Cindy Perez ; Howard Carrasquillo
          ; Robert Vilensky 
          Subject: RE: Anderson- Forrest v. Seven Pines/Anderson et al. v. Seven Pines Assoc. Limited partnership
          // Cozen File No.: 00534381

          Hi Erica,

          Apologies. We had an oversight that our discovery demands and not our Answer were e-filed. Our
          Answer should be e-filed later today.
                                                                                                                                                                      5
FILED: WESTCHESTER COUNTY CLERK 07/18/2023 04:15 PM                                                                                                                                                           INDEX NO. 64252/2021
NYSCEF DOC. NO. 69                                                                                                                                                                                     RECEIVED NYSCEF: 07/18/2023


          Once it is e-filed, you can sign the Stipulation to consolidate for our office.

          Thanks!

          Joel

                                                                                                                                         Joel M. Maxwell
                  To help protect y ou r priv acy , Microsoft O ffice prev ented automatic download of this picture from the Internet.   Member | Cozen O'Connor
                                                                                                                                         3 WTC, 175 Greenwich Street 55th Floor | New York, NY 10007
                                                                                                                                         P: 212-908-1359 F: 646-225-5109 C: 516-639-4564
                                                                                                                                         Email | Map | cozen.com




          From: Erica Podolsky 
          Sent: Friday, June 2, 2023 9:26 AM
          To: Maxwell, Joel M. ; 'John A. Risi' ; Panoyan, Susan E.
          
          Cc: Arlene Ilg ; Cindy Perez ; Howard Carrasquillo
          ; Robert Vilensky 
          Subject: RE: Anderson- Forrest v. Seven Pines/Anderson et al. v. Seven Pines Assoc. Limited partnership
          // Cozen File No.: 00534381

          **EXTERNAL SENDER**

          Dear Counselors, please see attached correspondence. Also attached is an updated stipulation to
          consolidate Forrest, Zayas and Kabba with Anderson. We still have not received answers in the Forrest
          case (Index number 58165/2023) although combined demands were filed by Conzen’s office. Please file
          answers in Forrest and sign the attached stip to consolidate, or advise if I can sign on your behalf.

          Thank you

          Erica

          From: Erica Podolsky
          Sent: Wednesday, May 10, 2023 10:44 AM
          To: 'Maxwell, Joel M.' ; 'John A. Risi' ; Panoyan, Susan
          E. 
          Subject: RE: Anderson- Forrest v. Seven Pines/Anderson et al. v. Seven Pines Assoc. Limited partnership
          // Cozen File No.: 00534381

          Hello All, the bops for plaintiff’s O’Goremann and McKennie were E-filed on March 10, 2023 (document
          # 50-52). Please update your files accordingly.

          Thank you,

          Erica

          From: Maxwell, Joel M. 
          Sent: Tuesday, May 9, 2023 11:55 AM
          To: Erica Podolsky ; 'John A. Risi' ; Panoyan, Susan
          E. 
          Cc: Christine Diaz ; Nadia Lescott ; Howard Carrasquillo
                                                                                                                                                                       6
FILED: WESTCHESTER COUNTY CLERK 07/18/2023 04:15 PM                                                                                                                                                           INDEX NO. 64252/2021
NYSCEF DOC. NO. 69                                                                                                                                                                                     RECEIVED NYSCEF: 07/18/2023
          ; Arlene Ilg ; Robert Vilensky
          ; Cindy Perez 
          Subject: RE: Anderson- Forrest v. Seven Pines/Anderson et al. v. Seven Pines Assoc. Limited partnership
          // Cozen File No.: 00534381

          Hi All,

          My paralegal broke up the authorizations we need by individual plaintiffs. See attached.

          Thanks!

          Joel

                                                                                                                                         Joel M. Maxwell
                  To help protect y ou r priv acy , Microsoft O ffice prev ented automatic download of this picture from the Internet.   Member | Cozen O'Connor
                                                                                                                                         3 WTC, 175 Greenwich Street 55th Floor | New York, NY 10007
                                                                                                                                         P: 212-908-1359 F: 646-225-5109 C: 516-639-4564
                                                                                                                                         Email | Map | cozen.com




          From: Erica Podolsky 
          Sent: Tuesday, May 9, 2023 10:27 AM
          To: Maxwell, Joel M. ; 'John A. Risi' ; Panoyan, Susan E.
          
          Cc: Christine Diaz ; Nadia Lescott ; Howard Carrasquillo
          ; Arlene Ilg ; Robert Vilensky
          ; Cindy Perez 
          Subject: Anderson- Forrest v. Seven Pines/Anderson et al. v. Seven Pines Assoc. Limited partnership //
          Cozen File No.: 00534381

          **EXTERNAL SENDER**

          Good morning counselors, Arlene Ilg will be covering for me on the conference today. I was reviewing
          this file and I see that we had commenced an action for plaintiff Akil forrest- your offices had agreed to
          accept service for this client. See below. Once the answers are e-filed, I will add this case to the
          stipulation to consolidate. I know we just did a stip, but its probably easier to consolidate Forrest along
          with the others in the same stip. Please file answers I will update the stip. Thank you for your courtesies
          in this matter.

          Also, per the last order depositions of plaintiffs Anderson, Appia and Akal are to be held in June. We
          intend to move forward with these depositions on the dates reflected in the CC order. If any
          authorizations are outstanding please advise at the conference today so that we can make sure that
          these depositions go forward as scheduled.

          Thank you

          Erica
          From: Maxwell, Joel M. 
          Sent: Tuesday, April 4, 2023 9:06 AM
          To: Erica Podolsky ; 'John A. Risi' ; Panoyan, Susan
          E. 
          Cc: Christine Diaz ; Nadia Lescott ; Howard Carrasquillo
          

                                                                                                                                                                       7
FILED: WESTCHESTER COUNTY CLERK 07/18/2023 04:15 PM                                                                                                                                                           INDEX NO. 64252/2021
NYSCEF DOC. NO. 69                                                                                                                                                                                     RECEIVED NYSCEF: 07/18/2023
          Subject: RE: Forrest v. Seven Pines/Anderson et al. v. Seven Pines Assoc. Limited partnership // Cozen
          File No.: 00534381

          Hi Erica,

          Appreciated! I will get you the Answer as soon as I can, but within 30 days.

          Thanks,

          Joel

                                                                                                                                         Joel M. Maxwell
                  To help protect y ou r priv acy , Microsoft O ffice prev ented automatic download of this picture from the Internet.   Member | Cozen O'Connor
                                                                                                                                         3 WTC, 175 Greenwich Street 55th Floor | New York, NY 10007
                                                                                                                                         P: 212-908-1359 F: 646-225-5109 C: 516-639-4564
                                                                                                                                         Email | Map | cozen.com




          From: Erica Podolsky 
          Sent: Tuesday, April 4, 2023 7:31 AM
          To: Maxwell, Joel M. ; 'John A. Risi' ; Panoyan, Susan E.
          
          Cc: Christine Diaz ; Nadia Lescott ; Howard Carrasquillo
          
          Subject: RE: Forrest v. Seven Pines/Anderson et al. v. Seven Pines Assoc. Limited partnership // Cozen
          File No.: 00534381

          **EXTERNAL SENDER**

          Good morning,

          Joel, Thank you for the update. 30 days to answer is fine. I have a stip to consolidate all the cases ready
          to go, once the answers are filed on this new case I will circulate it. Thank you all for your courtesies in
          this matter.

          Erica

          From: Maxwell, Joel M. 
          Sent: Monday, April 3, 2023 2:43 PM
          To: Erica Podolsky ; 'John A. Risi' ; Panoyan, Susan
          E. 
          Cc: Robert Vilensky ; Christine Diaz ; Nadia Lescott
          ; Howard Carrasquillo 
          Subject: Forrest v. Seven Pines/Anderson et al. v. Seven Pines Assoc. Limited partnership // Cozen File
          No.: 00534381

          Hi Erica,

          We have received approval to accept service of the Complaint in Forrest. Please give us 30 days to serve
          an Answer. We would also like to stipulate to consolidate all cases together.

          If you would like to discuss, please do not hesitate to contact us. My cell is 516-639-4564.


                                                                                                                                                                       8
FILED: WESTCHESTER COUNTY CLERK 07/18/2023 04:15 PM                                                                                                                                                          INDEX NO. 64252/2021
NYSCEF DOC. NO. 69                                                                                                                                                                                    RECEIVED NYSCEF: 07/18/2023
          Thanks,

          Joel

                                                                                                                                        Joel M. Maxwell
                 To help protect y ou r priv acy , Microsoft O ffice prev ented automatic download of this picture from the Internet.   Member | Cozen O'Connor
                                                                                                                                        3 WTC, 175 Greenwich Street 55th Floor | New York, NY 10007
                                                                                                                                        P: 212-908-1359 F: 646-225-5109 C: 516-639-4564
                                                                                                                                        Email | Map | cozen.com




          From: Maxwell, Joel M.
          Sent: Monday, April 3, 2023 11:02 AM
          To: 'Erica Podolsky' ; 'John A. Risi' ; Panoyan, Susan
          E. 
          Cc: Robert Vilensky ; Christine Diaz ; Nadia Lescott
          ; Howard Carrasquillo 
          Subject: RE: Forrest v. Seven Pines/Anderson et al. v. Seven Pines Assoc. Limited partnership // Cozen
          File No.: 00534381

          Hi Erica,

          Thank you for providing this. We will check with our clients and get back to you regarding accepting
          service. Personally, I see no issue, but this is not up to me.

          Thanks,

          Joel

                                                                                                                                        Joel M. Maxwell
                 To help protect y ou r priv acy , Microsoft O ffice prev ented automatic download of this picture from the Internet.   Member | Cozen O'Connor
                                                                                                                                        3 WTC, 175 Greenwich Street 55th Floor | New York, NY 10007
                                                                                                                                        P: 212-908-1359 F: 646-225-5109 C: 516-639-4564
                                                                                                                                        Email | Map | cozen.com




          From: Erica Podolsky 
          Sent: Monday, April 3, 2023 10:32 AM
          To: Maxwell, Joel M. ; 'John A. Risi' ; Panoyan, Susan E.
          
          Cc: Robert Vilensky ; Christine Diaz ; Nadia Lescott
          ; Howard Carrasquillo 
          Subject: RE: Forrest v. Seven Pines/Anderson et al. v. Seven Pines Assoc. Limited partnership

          **EXTERNAL SENDER**

          Good morning Counselors:

          As was mentioned at the last conference, this office has commenced a new action on behalf of plaintiffs
          AKIL FORREST and ANTOINETTE SILVA. This new action is related to the Anderson v. Seven Pines et
          al. action, containing the same defendants and same allegations. Attached is a copy of the E-filed
          summons and complaint. Please advise if your offices will accept service on behalf of your clients, or if
          they must be served by process server.
          Thank you,

                                                                                                                                                                      9
FILED: WESTCHESTER COUNTY CLERK 07/18/2023 04:15 PM                                            INDEX NO. 64252/2021
NYSCEF DOC. NO. 69                                                                    RECEIVED NYSCEF: 07/18/2023
          Erica Podolsky
          Ronemus and Vilensky, LLP

          CONFIDENTIALITY NOTE: This E-mail is intended only for the person or entity to which it is
          addressed and may contain information that is privileged, confidential or otherwise protected
          from disclosure. Dissemination, distribution, or copying of this E-mail or the information herein
          by anyone other than the intended recipient, is prohibited. If you have received this E-mail in
          error, please notify sender immediately by telephone at (212) 779-7070


          Notice: This communication, including attachments, may contain information that is
          confidential and protected by the attorney/client or other privileges. It constitutes non-
          public information intended to be conveyed only to the designated recipient(s). If the reader
          or recipient of this communication is not the intended recipient, an employee or agent of the
          intended recipient who is responsible for delivering it to the intended recipient, or you
          believe that you have received this communication in error, please notify the sender
          immediately by return e-mail and promptly delete this e-mail, including attachments without
          reading or saving them in any manner. The unauthorized use, dissemination, distribution, or
          reproduction of this e-mail, including attachments, is prohibited and may be unlawful.
          Receipt by anyone other than the intended recipient(s) is not a waiver of any attorney/client
          or other privilege.


          Notice: This communication, including attachments, may contain information that is
          confidential and protected by the attorney/client or other privileges. It constitutes non-
          public information intended to be conveyed only to the designated recipient(s). If the reader
          or recipient of this communication is not the intended recipient, an employee or agent of the
          intended recipient who is responsible for delivering it to the intended recipient, or you
          believe that you have received this communication in error, please notify the sender
          immediately by return e-mail and promptly delete this e-mail, including attachments without
          reading or saving them in any manner. The unauthorized use, dissemination, distribution, or
          reproduction of this e-mail, including attachments, is prohibited and may be unlawful.
          Receipt by anyone other than the intended recipient(s) is not a waiver of any attorney/client
          or other privilege.


          Notice: This communication, including attachments, may contain information that is
          confidential and protected by the attorney/client or other privileges. It constitutes non-
          public information intended to be conveyed only to the designated recipient(s). If the reader
          or recipient of this communication is not the intended recipient, an employee or agent of the
          intended recipient who is responsible for delivering it to the intended recipient, or you
          believe that you have received this communication in error, please notify the sender
          immediately by return e-mail and promptly delete this e-mail, including attachments without
          reading or saving them in any manner. The unauthorized use, dissemination, distribution, or
          reproduction of this e-mail, including attachments, is prohibited and may be unlawful.
          Receipt by anyone other than the intended recipient(s) is not a waiver of any attorney/client
          or other privilege.


          Notice: This communication, including attachments, may contain information that is
          confidential and protected by the attorney/client or other privileges. It constitutes non-
          public information intended to be conveyed only to the designated recipient(s). If the reader
          or recipient of this communication is not the intended recipient, an employee or agent of the
          intended recipient who is responsible for delivering it to the intended recipient, or you
          believe that you have received this communication in error, please notify the sender
          immediately by return e-mail and promptly delete this e-mail, including attachments without
          reading or saving them in any manner. The unauthorized use, dissemination, distribution, or
                                                          10
FILED: WESTCHESTER COUNTY CLERK 07/18/2023 04:15 PM                                        INDEX NO. 64252/2021
NYSCEF DOC. NO. 69                                                                 RECEIVED NYSCEF: 07/18/2023
          reproduction of this e-mail, including attachments, is prohibited and may be unlawful.
          Receipt by anyone other than the intended recipient(s) is not a waiver of any attorney/client
          or other privilege.


          Notice: This communication, including attachments, may contain information that is
          confidential and protected by the attorney/client or other privileges. It constitutes non-
          public information intended to be conveyed only to the designated recipient(s). If the reader
          or recipient of this communication is not the intended recipient, an employee or agent of the
          intended recipient who is responsible for delivering it to the intended recipient, or you
          believe that you have received this communication in error, please notify the sender
          immediately by return e-mail and promptly delete this e-mail, including attachments without
          reading or saving them in any manner. The unauthorized use, dissemination, distribution, or
          reproduction of this e-mail, including attachments, is prohibited and may be unlawful.
          Receipt by anyone other than the intended recipient(s) is not a waiver of any attorney/client
          or other privilege.
          




                                                       11
FILED: WESTCHESTER COUNTY CLERK 07/18/2023 04:15 PM                                                    INDEX NO. 64252/2021
NYSCEF DOC. NO. 69                                                                           RECEIVED NYSCEF: 07/18/2023


    Christine Diaz

    From:                            Arlene Ilg
    Sent:                            June 1, 2023 12:33 PM
    To:                              'jrisi@pmtlawfirm.com'
    Cc:                              AdamBernstein (AdamBernstein@brkblaw.com); 'SPanoyan@cozen.com';
                                     'carl@fingerandfinger.com'; Robert Vilensky; Howard Carrasquillo; Christine Diaz; Nadia
                                     Lescott; Auden Robertson
    Subject:                         Anderson v. Seven Pine Associates
    Attachments:                     good faith letter to defts - 114507.pdf


    Hi John,
    In follow up to my prior phone calls, please see a ached correspondence.
    Have a nice day.
    Arlene

    Arlene Ilg
    Ronemus & Vilensky
    112 Madison Avenue
    New York, NY 10016
    Tel - 212-779-7070
    Cell – 631-205-8069
    Fax - 212-686-2490
    arlene.ilg@ronvil.com




                                                               1
FILED: WESTCHESTER COUNTY CLERK 07/18/2023 04:15 PM                                                    INDEX NO. 64252/2021
NYSCEF DOC. NO. 69                                                                              RECEIVED NYSCEF: 07/18/2023




                                            112 M A D I S O N A V E N U E , 2 N D F L .
                                             N E W Y O R K , N E W Y O R K 10016
                                                 Tel (212) 779-7070
                                                 Fax (212) 686-2490

                                                                       Thursday, June 1, 2023

          John Risi
          Pillinger Miller Tarallo, LLP
          570 Taxter Road, Suite 275
          Elmsford, NY 10523
          Via email: jrisi@pmtlawfirm.com

          Re:    Anderson v. Seven Pine Associates Limited Partnership, Index No.: 64252/2021

          Dear John,

                   A review of our file indicated that defendants Seven Pine Associates Limited
          Partnership and H&S Property Management, Inc. have yet to respond to plaintiff’s combined
          demands dated September 19, 2022 or the preliminary conference order dated October 17, 2022.
           Please allow this correspondence to serve as a good faith attempt to obtain outstanding
          discovery and provide responses, particularly a response to plaintiff’s demand for insurance and
          excess coverage, upon receipt to avoid further delays or unnecessary motion practice.

                 Should you have any questions, please do not hesitate to contact this office.

                                                                       Very truly yours,
                                                                       Arlene Ilg
                                                                       Arlene Ilg

          Cc:
          Budin, Reisman, Kupferberg & Bernstein
          112 Madison Avenue, 2nd Floor
          New York, NY 10016
          Adam.Bernstein@brkblaw.com

          Cozen O'Connor
          45 Broadway, 16th Floor
          New York, NY 10006
          SPanoyan@cozen.com

          Finger & Finger
          158 Grand Street
          White Plains, NY 10601
          carl@fingerandfinger.com