Letter,Correspondence: Pearl Delta Funding, Llc v. Peak Title Agency Co. A/K/A PEAK TITLE CO, Tobby Jablonski, Juan Ruiz Jr

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                                FILED: NASSAU COUNTY CLERK 09/19/2023 12:34 PM                                                      INDEX NO. 600378/2023
NYSCEF DOC. NO. 93                                                                         RECEIVED NYSCEF: 09/19/2023




                                                 September 19, 2023

          Via NYSCEF and E-Mail:
          Hon. Conrad D. Singer, J.S.C.
          Supreme Court, Nassau County
          100 Supreme Court Drive
          Mineola, New York 11501

                 Re:     Pearl Delta Funding, LLC v. Peak Title Agency Co., et al.
                         Index No. 600378/2023
                         Re: Plaintiff’s Proposed Order

          Dear Judge Singer:

                  My office represents Plaintiff Pearl Delta Funding, LLC (“Plaintiff”). I write in connection
          with Plaintiff’s Proposed Order filed herewith. At the conference held in this matter on August
          29, 2023, the Court directed the parties to exchange proposed stipulations regarding outstanding
          discovery and subsequently meet-and-confer regarding said proposed stipulations in an effort to
          resolve the ongoing dispute over Defendants’ non-compliance and, if possible, to submit a joint
          stipulation to the Court. To that end, Plaintiff sent a Proposed Stipulation to Defendants’ counsel
          on Monday, September 11, 2023, requesting that Defendants circulate their proposed stipulation
          at their earliest convenience, so that the parties could conduct the ordered meet-and-confer. On
          Thursday, September 14, 2023, having received no response, Plaintiff’s counsel, Phillip Spinella,
          attempted to reach Defendants’ counsel, Mr. Dale, by phone. Mr. Dale answered, but then, after
          being informed of who was calling, hung up, and sent subsequent calls to voicemail. Mr. Dale
          never otherwise responded to the follow-up emails or calls that were made between then and now.
          A copy of the referenced correspondence is annexed hereto.

                   In light of the foregoing, the Plaintiff has filed the stipulation that was circulated to
          Defendants’ counsel as a Proposed Order. The Proposed Order is identical in all material respects
          to the stipulation circulated to Defendants’ counsel, except for the removal of the signature blocks
          of the parties and an addition of one paragraph to the preamble, to correspond to the intervening
          events between its circulation and its submission now. Thank you kindly for the Court's attention
          to this matter. If the Court has any questions, comments, or concerns, please feel free to contact
          the undersigned.

                                                                          Sincerely,
                                                                          /s/ Phillip A. Spinella

          CC via NYSCEF:
          Counsel for all parties




                  170 Old Country Road             Office: 516-260-7367            cmurray@murraylegalpllc.com
                  Suite 608                                                        www.murraylegalpllc.com
                  Mineola, New York 11501




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