On November 21, 2023 a
Exhibit,Appendix
was filed
involving a dispute between
Melissa Gagliardi,
and
Scott Buckler,
for Commercial - Other (Injury to Business)
in the District Court of Westchester County.
Preview
FILED: WESTCHESTER COUNTY CLERK 11/21/2023 03:12 PM INDEX NO. 71167/2023
NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 11/21/2023
EXHIBIT 16
to Affirmation of Siano
FILED: WESTCHESTER COUNTY CLERK 11/21/2023 03:12 PM INDEX NO. 71167/2023
NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 11/21/2023
Fwd: zoom meeting
From: Melissa Gagliardi (mgagliardi9@gmail.com)
To: tonysiano@aol.com
Date: Monday, October 23, 2023 at 05:05 PM EDT
Hi Gina and Tony,
Another email from Buckler. Talk to you soon.
Take care,
Melissa Gagliardi
--- Forwarded message -----
From: Scott <.s_ce.gttybuckler@aol.com>
Date: Mon, Oct 23, 2023, 4:28 PM
Subject: zoom meeting
To: Melissa GagIlardi
Hello Melissa,
I wanted to follow up regarding the letter I sent on October 11, 2023, as I haven't received a
response. I presume you may have discussed it with your attorney, particularly concerning the
absence of a Non-Disclosure Agreement (NDA) or a non-disparagement clause in the general
release signed last March.
Today, I will be reaching out to Alex via email, extending an opportunity to schedule a Zoom
meeting for this week. The purpose of this meeting is to provide both you and Alex with the
Woman."
chance to share your perspectives on the events related to "Lines of a I am in the
process of compiling information, documentation, and conducting an investigative review of the
events. The resulting report will be made public.
I believe it's essential to afford each of you the opportunity to provide your accounts of the
discussions and negotiations that took place between you and Alex from February through July of
2021. Should Alex agree to the Zoom interview, he will have the opportunity to address any
commitments you may have made regarding his creative role and control in the project.
Should you-agree to the interview, you can also present your viewpoint, potentially highlighting
any circumstances where Alex may have sought undue control or engaged in a quid-pro-quo
arrangement.
Recognizing that 1 was not privy to your private discussions, my intention is not to speculate but
rather to present a comprehensive and fair account of the events. Both scenarios will be
considered. In your defense, the thorough documentation you provided under legal representation
suggests the possibility of external influence. On the other hand, it's equally plausible that you
were navigating complex negotiations to your advantage.
FILED: WESTCHESTER COUNTY CLERK 11/21/2023 03:12 PM INDEX NO. 71167/2023
NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 11/21/2023
My objective is to offer my time for you and Alex to provide explanations for the questions I have. I
want to avoid drawing hasty conclusions based solely on the documentation I possess, as these
events may have been more intricate than they initially appear.
Woman"
The central concern is how the events surrounding "Lines of a may impact both Alex's
and your long-term professional reputations. While I do not possess the authority to compel your
cooperation, I emphasize that silence may not serve your interests. I am committed to Including
any statements you provide and affording you every reasonable opportunity to clarify your
position. The absence of a response will also be duly noted.
Please consider the consequences for both you and Alex regarding the project's impact on your
respective careers. While you have other income avenues and can potentially weather any
negative repercussions, Alex's standing in the industry may be significantly affected. He may not
have the luxury of waiting out negative publicity, and If he responds to the interview while you do
not, he may present a narrative that deflects responsibility. Without documentation to counter his
statements, he could potentially gain absolution. I strongly advise against a strategy that might
place the sole responsibility on you, as this may not align with your best interests.
I have previously provided written accounts outlining scenarios where you might have been
persuaded to take responsibility, along with supporting documentation. If this accurately
represents the situation, so be it. However, if this does not align with the truth, the upcoming
interview may be your opportunity to set the record straight.
I am offering you a platform to share your perspective, and I will conduct the interview in a fair and
non-antagonistic manner. Your truthful statements will be considered to ensure the highest level of
accuracy possible. I believe an interview format, as opposed to written statements, will best
facilitate the clarification of your position.
Thank you for your attention to this matter.
Sincerely,
Scott
Document Filed Date
November 21, 2023
Case Filing Date
November 21, 2023
Category
Commercial - Other (Injury to Business)
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Preview
FILED: WESTCHESTER COUNTY CLERK 11/21/2023 03:12 PM INDEX NO. 71167/2023 NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 11/21/2023 EXHIBIT 16 to Affirmation of Siano FILED: WESTCHESTER COUNTY CLERK 11/21/2023 03:12 PM INDEX NO. 71167/2023 NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 11/21/2023 Fwd: zoom meeting From: Melissa Gagliardi (mgagliardi9@gmail.com) To: tonysiano@aol.com Date: Monday, October 23, 2023 at 05:05 PM EDT Hi Gina and Tony, Another email from Buckler. Talk to you soon. Take care, Melissa Gagliardi --- Forwarded message ----- From: Scott <.s_ce.gttybuckler@aol.com> Date: Mon, Oct 23, 2023, 4:28 PM Subject: zoom meeting To: Melissa GagIlardi Hello Melissa, I wanted to follow up regarding the letter I sent on October 11, 2023, as I haven't received a response. I presume you may have discussed it with your attorney, particularly concerning the absence of a Non-Disclosure Agreement (NDA) or a non-disparagement clause in the general release signed last March. Today, I will be reaching out to Alex via email, extending an opportunity to schedule a Zoom meeting for this week. The purpose of this meeting is to provide both you and Alex with the Woman." chance to share your perspectives on the events related to "Lines of a I am in the process of compiling information, documentation, and conducting an investigative review of the events. The resulting report will be made public. I believe it's essential to afford each of you the opportunity to provide your accounts of the discussions and negotiations that took place between you and Alex from February through July of 2021. Should Alex agree to the Zoom interview, he will have the opportunity to address any commitments you may have made regarding his creative role and control in the project. Should you-agree to the interview, you can also present your viewpoint, potentially highlighting any circumstances where Alex may have sought undue control or engaged in a quid-pro-quo arrangement. Recognizing that 1 was not privy to your private discussions, my intention is not to speculate but rather to present a comprehensive and fair account of the events. Both scenarios will be considered. In your defense, the thorough documentation you provided under legal representation suggests the possibility of external influence. On the other hand, it's equally plausible that you were navigating complex negotiations to your advantage. FILED: WESTCHESTER COUNTY CLERK 11/21/2023 03:12 PM INDEX NO. 71167/2023 NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 11/21/2023 My objective is to offer my time for you and Alex to provide explanations for the questions I have. I want to avoid drawing hasty conclusions based solely on the documentation I possess, as these events may have been more intricate than they initially appear. Woman" The central concern is how the events surrounding "Lines of a may impact both Alex's and your long-term professional reputations. While I do not possess the authority to compel your cooperation, I emphasize that silence may not serve your interests. I am committed to Including any statements you provide and affording you every reasonable opportunity to clarify your position. The absence of a response will also be duly noted. Please consider the consequences for both you and Alex regarding the project's impact on your respective careers. While you have other income avenues and can potentially weather any negative repercussions, Alex's standing in the industry may be significantly affected. He may not have the luxury of waiting out negative publicity, and If he responds to the interview while you do not, he may present a narrative that deflects responsibility. Without documentation to counter his statements, he could potentially gain absolution. I strongly advise against a strategy that might place the sole responsibility on you, as this may not align with your best interests. I have previously provided written accounts outlining scenarios where you might have been persuaded to take responsibility, along with supporting documentation. If this accurately represents the situation, so be it. However, if this does not align with the truth, the upcoming interview may be your opportunity to set the record straight. I am offering you a platform to share your perspective, and I will conduct the interview in a fair and non-antagonistic manner. Your truthful statements will be considered to ensure the highest level of accuracy possible. I believe an interview format, as opposed to written statements, will best facilitate the clarification of your position. Thank you for your attention to this matter. Sincerely, Scott