On July 23, 2021 a
Exhibit,Appendix
was filed
involving a dispute between
Michael Buxbaum,
and
Adam Kurland,
for Torts - Other (Tort)
in the District Court of Rockland County.
Preview
FILED: ROCKLAND COUNTY CLERK 07/29/2021 09:05 AM INDEX NO. 034367/2021
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 07/29/2021
Jocelyn Hill
Re: Buxbaum v Kurland
1 message
michael bt!xbat!m Mon, Jul 26, 2021 at 9:29 AM
To: Adam Kurland
Cc: Katherine Kivlehan , Jocelyn Hill
Adam Kurland, Individual and Attorney
1- The lawsuit will be prosecuted
fully and completely and expansively and
will not be withdrawn.
2- Kindly note my Summons and Complaint.
3- This uunciüdes
my email communications to all your de minimis caramüñ|cations.
-Michael Buxbaum
On Jul 26, 2021, at 9:21 AM, Adam Kurland wrote:
Mr. Buxbaum,
I am in receipt of your Summons and Complaint wherein you appear to assert claims against me.
Cutting to the chase, your claims are patently devoid of any merit and are patently frivolous.
The universe of our intera t!ess, which have been minimal, relate SOLELY to my position as attorney for the Georgetown Office Plaza
CGñdGrainium ("Georgetown") and your failure and/or refusal, as an owner of a corñmarcia| unit in the complex, to pay common
charges. Nothing more. And when GêGrgetawn commenced an action against you, you replied with a counterclaim, cüñtaining
allegations equally as frivolous as those cüñtõiñGd in the within suit. Those counterclaims were dismissed by the court upon
GeGig6tawa's motion. In that suit, we are now engaged in discovery, which includes my properly noticing you for a depee!tion.
So, while I doubt that based upon the foregoing you will withdraw your camp|aiñt with prejudice, please let this email serve as notice
that if you do not do so by the close of business July 27, 2021, my motion to dismiss will sdd!tices!!y contain a request for the
imposition of costs and expenses, inc|üding legal fees and sanctions, against you.
Be guided accordingly.
Adam K. Kurland, Esq.
ADAM K. KURLAND, ATTORNEY AT LAW, P.C.
337 North Main Street
Suite 11
New City, New York 10956
(845) 638-4700
(845) 638-4767-Fax
akurland@akkpc.com
www.adamkurlandlaw.com
NOTE: The information in this email is confidential and may be legally privi|6ged. If you are not the intended recipient, you must not
read, use or disseminate the information. Although this email and any attachrñents are believed to be free of any virus or other defect
that might affect any computer system into which it is received and opened, it is the responsibility of the recipient to ensure that it is
virus free and no respcasibility is accepted by ADAM K. KURLAND, ATTORNEY AT LAW, P.C. for any loss or damage arising in any
way from its use.
Document Filed Date
July 29, 2021
Case Filing Date
July 23, 2021
Category
Torts - Other (Tort)
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED: ROCKLAND COUNTY CLERK 07/29/2021 09:05 AM INDEX NO. 034367/2021 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 07/29/2021 Jocelyn Hill Re: Buxbaum v Kurland 1 message michael bt!xbat!m Mon, Jul 26, 2021 at 9:29 AM To: Adam Kurland Cc: Katherine Kivlehan , Jocelyn Hill Adam Kurland, Individual and Attorney 1- The lawsuit will be prosecuted fully and completely and expansively and will not be withdrawn. 2- Kindly note my Summons and Complaint. 3- This uunciüdes my email communications to all your de minimis caramüñ|cations. -Michael Buxbaum On Jul 26, 2021, at 9:21 AM, Adam Kurland wrote: Mr. Buxbaum, I am in receipt of your Summons and Complaint wherein you appear to assert claims against me. Cutting to the chase, your claims are patently devoid of any merit and are patently frivolous. The universe of our intera t!ess, which have been minimal, relate SOLELY to my position as attorney for the Georgetown Office Plaza CGñdGrainium ("Georgetown") and your failure and/or refusal, as an owner of a corñmarcia| unit in the complex, to pay common charges. Nothing more. And when GêGrgetawn commenced an action against you, you replied with a counterclaim, cüñtaining allegations equally as frivolous as those cüñtõiñGd in the within suit. Those counterclaims were dismissed by the court upon GeGig6tawa's motion. In that suit, we are now engaged in discovery, which includes my properly noticing you for a depee!tion. So, while I doubt that based upon the foregoing you will withdraw your camp|aiñt with prejudice, please let this email serve as notice that if you do not do so by the close of business July 27, 2021, my motion to dismiss will sdd!tices!!y contain a request for the imposition of costs and expenses, inc|üding legal fees and sanctions, against you. Be guided accordingly. Adam K. Kurland, Esq. ADAM K. KURLAND, ATTORNEY AT LAW, P.C. 337 North Main Street Suite 11 New City, New York 10956 (845) 638-4700 (845) 638-4767-Fax akurland@akkpc.com www.adamkurlandlaw.com NOTE: The information in this email is confidential and may be legally privi|6ged. If you are not the intended recipient, you must not read, use or disseminate the information. Although this email and any attachrñents are believed to be free of any virus or other defect that might affect any computer system into which it is received and opened, it is the responsibility of the recipient to ensure that it is virus free and no respcasibility is accepted by ADAM K. KURLAND, ATTORNEY AT LAW, P.C. for any loss or damage arising in any way from its use.