Exhibit,Appendix: Proedge Remodeling, Inc. A/K/A Custom Built, Inc. v. Joseph Careccia, Michael A. Barton

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                                FILED: ALBANY COUNTY CLERK 08/01/2023 05:34 PM           INDEX NO. 907205-23
NYSCEF DOC. NO. 8                                RECEIVED NYSCEF: 08/01/2023




                             Exhibit A
FILED: ALBANY COUNTY CLERK 08/01/2023 05:34 PM                                                                 INDEX NO. 907205-23
NYSCEF DOC. NO. 8                                                                                  RECEIVED NYSCEF: 08/01/2023


    Bonnie R. Watson

    From:                         Bonnie R. Watson
    Sent:                         Tuesday, August 01, 2023 5:08 PM
    To:                           'Joecareccia1@gmail.com'
    Cc:                           Daniel S. Rubin
    Subject:                      ProEdge Remodeling v. Careccia & Barton - Forthcoming Application for Temporary Restraining
                                  Order
    Attachments:                  Summons & Complaint (with exhibits).pdf; OTSC [proposed].pdf; Aff Thomas (with exhibits).pdf; Aff
                                  BRW.pdf



    Dear Mr. Careccia:

    As you are aware from our prior correspondence of July 19, 2023, Girvin & Ferlazzo, P.C. represents Proedge
    Remodeling, Inc. a/k/a Custom Built, Inc. (“Plain ff”) in connec on with disputes arising out of your non-solicita on
    agreement with Plain ff.

    Pursuant to Rules 202.7(f) and 202.8-e of the Uniform Civil Rules for the Supreme Court, I write to provide you with
    advance no ce that Plain ff will be filing the a ached papers with the Albany County Supreme Court this a ernoon,
    August 1, 2023. These papers include a Summons and Complaint commencing a lawsuit against you, as well as a
    proposed Order to Show Cause reques ng that the court issue a temporary restraining order and preliminary injunc on
    which would prohibit you from recrui ng employees of Plain ff while the lawsuit is pending. Plain ff’s court filings will
    be submi ed electronically via the New York State Courts Electronic Filing (NYSCEF) system.

    A ached to this le er are copies of the papers which we will be filing with the court: (1) a Summons and Complaint with
    exhibits, (2) a proposed Order to Show Cause for the court to issue, (3) an affidavit by Beth Thomas on Plain ff’s behalf,
    with exhibits, and (4) my a orney affirma on presen ng Plain ff’s legal arguments for an injunc on/restraining order
    (this email to you, and an equivalent email to your co-defendant, will become the documents iden fied as “Exhibits A
    and B” in my affirma on).

    Once we have electronically filed these papers, the court clerk will assign an index number and a judge to the case, and
    will forward our proposed Order to Show Cause to the judge. Once we receive the signed Order to Show Cause (which
    will include the case’s index number and iden fy which judge has been assigned to the case), we will pass this
    informa on on to you promptly.

    We an cipate that as part of processing and issuing the Order to Show Cause, the court will schedule a hearing on our
    applica on for an injunc on, which will give you an opportunity to appear and be heard in this ma er.

    Please forward these materials to your legal counsel immediately, as the failure to take ac on could prejudice your
    rights in this ma er.

    Bonnie R. Watson, Esq.
    Associate Attorney
    Girvin & Ferlazzo, P.C.
    20 Corporate Woods Blvd.
    Albany, NY 12211
    (518) 462-0300 (office)
    (518) 590-2995 (cell)
    (518) 462-5037 (fax)
    brw@girvinlaw.com


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FILED: ALBANY COUNTY CLERK 08/01/2023 05:34 PM           INDEX NO. 907205-23
NYSCEF DOC. NO. 8                                RECEIVED NYSCEF: 08/01/2023




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