On December 16, 2021 a
Exhibit,Appendix
was filed
involving a dispute between
Dab Realty Corporation,
and
1001 Rogers Ave Llc,
for Real Property - Other (Removal of Encroachment)
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 10/20/2023 03:25 PM INDEX NO. 532178/2021
NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 10/20/2023
EXHIBIT
E
FILED: KINGS COUNTY CLERK 10/20/2023 03:25 PM INDEX NO. 532178/2021
NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 10/20/2023
From: Steven Foceri
To: valentine.law.firm.pc@gmail.com
Cc: Lisa M. Fitzgerald
Subject: 0200626 : DAB Realty Corporation v. 1001 Rogers Ave LLC : :
Date: Tuesday, August 15, 2023 3:54:17 PM
Attachments: DAB Realty Corp. - 2nd GF letter to PL SENT 8.15.2023.pdf
Hello,
Please see the attached for the above-mentioned matter. Please note that a hard copy of this letter is being sent in the mail today as
well. Thank you and have a nice evening.
Very truly,
Steven Foceri, NY Litigation Practice Assistant
​
Weber Gallagher
1500 Broadway, Suite 2401
New York, NY 10036
T: 646.585.7132 F: 929.342.6001
sfoceri@wglaw.com, www.wglaw.com
Confidentiality Note: The information contained in this electronic message may contain attorney-client privileged and confidential information intended only for the use of the owner of
the email address listed as the recipient of this message. If you are not the intended recipient of this email message you are hereby notified that any disclosure, dissemination,
distribution, or copying of this communication is strictly prohibited. If you have received this transmission in error, please notify the sender by return email; and by telephone at
973.242.1364.
Weber Gallagher Simpson Stapleton Fires & Newby LLPÂ Â
FILED: KINGS COUNTY CLERK 10/20/2023 03:25 PM INDEX NO. 532178/2021
NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 10/20/2023
1500 Broadway, Suite 2401 T (646) 585-7120
New York, NY 10036 F(929) 342-6001
August 15, 2023
Via E-Mail and 1st Class U.S. Mail - valentine.law.firm.pc@gmail.com
THE VALENTINE LAW FIRM, PLLC Direct Dial: (646) 585.7122
Email: lfitzgerald@wglaw.com
225 Broadway, 3rd floor
New York, New York 10007
Attn: Michael A. Valentine, Esq.
Re: DAB Realty Corporation v. 1001 Rogers Ave LLC
Index No.: 532178/2021 (Kings County Supreme Court)
DOL: 2/13/2020
Our File No.: 0200626
Dear Mr. Valentine:
We represent Defendant, 1001 Rogers Ave LLC in the above-captioned lawsuit.
On December 8, 2022, we served you with Defendant’s Combined Discovery Demands
including a Demand for a Verified Bill of Particulars. On April 6, 2022, we wrote to you regarding
the status of these responses and requested that you provide the outstanding discovery as soon as
possible. We spoke on May 3, 2023 and were told the responses would be forthcoming. Still,
Defendant has not received responses to our discovery demands. Accordingly, we ask that you
provide this outstanding discovery as soon as possible. If we do not receive a response within
seven (7) days, we will seek the court’s intervention.
Please consider this letter an attempt in good faith to resolve these issues of discovery
pursuant to 22 N.Y.C.R.R. § 202.7. Please provide the outstanding discovery responses as soon
as possible.
Thank you for your anticipated courtesy and cooperation. Should you have any questions,
please feel free to contact me.
Very truly yours,
Lisa M. Fitzgerald
Lisa M. Fitzgerald
LMF/sf
Document Filed Date
October 20, 2023
Case Filing Date
December 16, 2021
Category
Real Property - Other (Removal of Encroachment)
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FILED: KINGS COUNTY CLERK 10/20/2023 03:25 PM INDEX NO. 532178/2021 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 10/20/2023 EXHIBIT E FILED: KINGS COUNTY CLERK 10/20/2023 03:25 PM INDEX NO. 532178/2021 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 10/20/2023 From: Steven Foceri To: valentine.law.firm.pc@gmail.com Cc: Lisa M. Fitzgerald Subject: 0200626 : DAB Realty Corporation v. 1001 Rogers Ave LLC : : Date: Tuesday, August 15, 2023 3:54:17 PM Attachments: DAB Realty Corp. - 2nd GF letter to PL SENT 8.15.2023.pdf Hello, Please see the attached for the above-mentioned matter. Please note that a hard copy of this letter is being sent in the mail today as well. Thank you and have a nice evening. Very truly, Steven Foceri, NY Litigation Practice Assistant ​ Weber Gallagher 1500 Broadway, Suite 2401 New York, NY 10036 T: 646.585.7132 F: 929.342.6001 sfoceri@wglaw.com, www.wglaw.com Confidentiality Note: The information contained in this electronic message may contain attorney-client privileged and confidential information intended only for the use of the owner of the email address listed as the recipient of this message. If you are not the intended recipient of this email message you are hereby notified that any disclosure, dissemination, distribution, or copying of this communication is strictly prohibited. If you have received this transmission in error, please notify the sender by return email; and by telephone at 973.242.1364. Weber Gallagher Simpson Stapleton Fires & Newby LLP  FILED: KINGS COUNTY CLERK 10/20/2023 03:25 PM INDEX NO. 532178/2021 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 10/20/2023 1500 Broadway, Suite 2401 T (646) 585-7120 New York, NY 10036 F(929) 342-6001 August 15, 2023 Via E-Mail and 1st Class U.S. Mail - valentine.law.firm.pc@gmail.com THE VALENTINE LAW FIRM, PLLC Direct Dial: (646) 585.7122 Email: lfitzgerald@wglaw.com 225 Broadway, 3rd floor New York, New York 10007 Attn: Michael A. Valentine, Esq. Re: DAB Realty Corporation v. 1001 Rogers Ave LLC Index No.: 532178/2021 (Kings County Supreme Court) DOL: 2/13/2020 Our File No.: 0200626 Dear Mr. Valentine: We represent Defendant, 1001 Rogers Ave LLC in the above-captioned lawsuit. On December 8, 2022, we served you with Defendant’s Combined Discovery Demands including a Demand for a Verified Bill of Particulars. On April 6, 2022, we wrote to you regarding the status of these responses and requested that you provide the outstanding discovery as soon as possible. We spoke on May 3, 2023 and were told the responses would be forthcoming. Still, Defendant has not received responses to our discovery demands. Accordingly, we ask that you provide this outstanding discovery as soon as possible. If we do not receive a response within seven (7) days, we will seek the court’s intervention. Please consider this letter an attempt in good faith to resolve these issues of discovery pursuant to 22 N.Y.C.R.R. § 202.7. Please provide the outstanding discovery responses as soon as possible. Thank you for your anticipated courtesy and cooperation. Should you have any questions, please feel free to contact me. Very truly yours, Lisa M. Fitzgerald Lisa M. Fitzgerald LMF/sf