Preview
FILED: NEW YORK COUNTY CLERK 11/03/2021 05:54 PM INDEX NO. 152948/2020
NYSCEF DOC. NO. 157 RECEIVED NYSCEF: 11/03/2021
EXHIBIT “R”
EXHIBIT “R”
FILED: NEW YORK COUNTY CLERK 11/03/2021 05:54 PM INDEX NO. 152948/2020
NYSCEF DOC. NO. 157 RECEIVED NYSCEF: 11/03/2021
From: Susan Stromberg
Sent: Friday, September 17, 2021 6:13 PM
To: Brett Nomberg; SFC-PART23; Sasha Robins
Szybisty·
Cc: Dominika Anne Amatulli; Hon. Franc W Perry
Subject RE: Conference requested - Itara v. Masaryk,, et al Index # 152948/2020
PIs' Pls' - Dr.
Attach=ênts: Further Response to Demands for D&l 9.14.2021.PDF; Medical Exchange
Steven Touliopoulos.PDF
Dear Ms. Cangiano:
I am at a loss as to why Plaintiff's counsel continues to harangue the Court with unnecessary emails. I never
said that I refused to proceed with depositions unless they were held in person. Plaintiff wrote to the Court
requesting depositions via video, I requested them in person, and the issue is before the Court. I am available
for a conference call on Monday should the Court deem it necessary. However, an email from the Court with
regard to this issue should suffice, and I will abide by the Court's decision.
I will, however, take this opportunity to point out Plaintiff's counsel provided my office with a Medical
Exchange on September 14, 2021, three days ago, and two additional authorizations to obtain medical records
for surgery that Plaintiff apparently underweñt on August 9, 2021. Plaintiff did not provide the authorizations
for this surgery until September 14, 2021, more than a month after the surgery, and one week before
Plaintiff's scheduled deposition. Should the depositions go forward on September 21, either in person or via
video, we will reserve our right to a further deposition of the Plaintiff once the medical records are received
pursuant to these new authorizations.
Respectfully submitted,
Susan J. Stromberg
Susan J. Stromberg, Esq.
Partner
............................................
MMPaS
Milber Makris Plousadis & Seiden, LLP
1000 Woodbury Road, Suite 402
Woodbury, New York 11797
516.712.4000 ext.1103
516.870.1103 direct
516.712.4013 fax
sstromberq(Amilbermakris.corn
This electronic mail transmission is privileged and confidential and is intended only for the review of the party to whom it is addressed. If you have received this
transmission in error, please immediately retum it to the sender. Unintended transmission shall not constitute waiver of the attomey-client or any other privilege
For more information about MMP&S, please visit www.milbermakris.com.
From: Brett Nomberg
Sent: Friday, September 17, 2021 5:56 PM
To: SFC-PART23 ; Sasha Robins
Cc: Dominika Szybisty ; Anne Amatulli ; Susan Stromberg
1
FILED: NEW YORK COUNTY CLERK 11/03/2021 05:54 PM INDEX NO. 152948/2020
NYSCEF DOC. NO. 157 RECEIVED NYSCEF: 11/03/2021
; Hon. Franc W Perry
Subject: RE: Conference requested - itara v. Masaryk,, et al Index # 152948/2020
External Sender Dete_cted
This is an external email. Be certain that the message is really from the person it claims to be from (by
clicking on sender's name to verify email
address.) Be wary ofany links, login requests, attachments, or
requests for personal or financial information that appear below this advisory.
Ms. Cangiano, in light of defense counsel's refusal now to proceed with the depositions scheduled for Tuesday unless in
person, as well as the other issues that could not be resolved, I again request, in compliance with the part rules, a
conference call/video for Monday morning with the court.
Below is defense counsel's email in April giving no reason to believe she would have any issue if we did not want to
proceed in person. Since that time we have learned that even being vaccinated does not mean a person is not infected
and contagious with the Delta variant.
From: Susan Stromberg
Sent: Wednesday, April 28, 2021 4:00 PM
To: Dominika Szybisty ; Brett Nomberg
subject: RE: Itara
My client is available on June 17, 2021for his deposition. I have your client down for June 16.
Brett, we can discuss if these will be in person or virtual. I am very sensitive to this issue, and I do not want to make anyone feel
uncomfortable. Let's table this decision until the date gets closer, and we can see where we are with vaccinations and people's comfort levels.
Thanks,
Susan
Susan J. Stromberg, Esq.
Partner
............................................
MMP&S
MilberMakris Plousadis & Seiden, LLP
1000 Woodbury Road, Suite 402
Woodbury, New York 11797
516.712.4000 ext.1103
516.870.1103 direct
516.712.4013 fax
sstromberg@milbermakris.com
Respectfully,
Brett J. Nomberg
Brand Brand Nomberg & Rosenbaum, LLP
3d 7th
622 Avenue, Floor
New York, NY 10017
(212)808-0448
bnomberg@bbnrlaw.com
www.bbnrlaw.çqm
2
FILED: NEW YORK COUNTY CLERK 11/03/2021 05:54 PM INDEX NO. 152948/2020
NYSCEF DOC. NO. 157 RECEIVED NYSCEF: 11/03/2021
Notice
--
Confidentiality
------------- ----
This email and any files transmitted with it are confidential and intended solely for the use of the
individual or entity to whom they are addressed. If you are not the intended addressee, then you are
not permitted to disseminate, distribute or copy any medical information, dates of birth, or Social
Security numbers, or any other private information of such nature. Please notify the sender
immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your
system. If you are not the intended recipient you are notified that disclosing, copying,distributing or
taking any action in reliance on the contents of this information is strictly prohibited. Confidential
health information is protected by state and federal law, including, but not limited to, by the Health
Insurance Portability and Accountability Act of 1996 and related regulations.
From: SFC-PART23
Sent: Friday, September 17, 2021 10:31 AM
To: Sasha Robins ; SFC-PART23
Cc: Dominika Szybisty ; Anne Amatulli ; Brett Norñberg
; Susan Stromberg ; Hon. Franc W Perry
Subject: RE: Conference requested - Itara v. Masaryk,, et al Index # 152948/2020
Good morning counsel:
Justice Perry directs the parties to meet and confer to resolve the issue related to plaintiff's deposition presently
scheduled for September 21, 2021, in accordance with Uniform Rule Section 202.20-f (b) Disclosure Disputes,
which provides in pertinent part, "Absent exigent circumstances, prior to contacting the court regarding a
disclosure dispute, counsel must first consult with one another in a good faith effort to resolve all disputes about
conference."
disclosure. Such consultation must take place by an in-person or telephonic
In addition, please note that plaintiff's motion sequence number 002 and the defendant's cross motion, were
filed in violation of the above quoted rule and in violation of Justice Perry's Part Rules. Accordingly, the
parties are directed to meet and confer, in good faith, in order to resolve the discovery issues including
scheduling depositions, given that the third party defendant has recently appeared in this matter by filing a pre-
answer motion to dismiss which is returnable in Room 130 on October 4, 2021.
In the event that the parties cannot resolve this discovery dispute following good faith consultation and
withdraw the pending discovery motions, the court notes that there is already a remote compliance conference
scheduled in this matter on October 6, 2021 at 9:30. Alternatively, in lieu of appearing at the October 6 remote
conference, the parties are encouraged to resolve the issues and set forth new dates for any outstanding
discovery and schedule dates for depositions. Attached please find a blank Compliance Conference Order
which can be submitted to the Court for review and signature, in lieu of attending the October 6 remote
conference. Or, given the motion to dismiss, the parties may opt to adjourn the remote compliance
pending
conference. Finally, during these very trying times when we are all experiencing delays and other issues
from the pandemic, the parties are reminded of the importance of professional courtesy and
resulting
cooperation when dealing with one another.
Please advise the Court how you wish to proceed.
3
FILED: NEW YORK COUNTY CLERK 11/03/2021 05:54 PM INDEX NO. 152948/2020
NYSCEF DOC. NO. 157 RECEIVED NYSCEF: 11/03/2021
Nina Cangiano
Principal Law Clerk to the Hon. W. Franc Perry
Supreme Court of the State of New York
80 Centre Street-Room 307
New York, New York 10013
From: Sasha Robins [mailto:sasha.robins@babchikyoung.coml
Sent: Wednesday, September 15, 2021 5:40 PM
To: SFC-PART23
Cc: Dominika Szybisty ; Anne Amatulli ; Brett NGmbêig
; Susan Stromberg
Subject: RE: Conference requested - Itara v. et at Index # 152948/2020
Masaryk,,
Dear Justice Perry:
We represent Third-Party Defendant Centennial Elevator Industries, Plaintiff's employer. I would also appreciate a brief
conference with the Court. As can be seen by my motion to dismiss, I have just appeared in the action, and would not
be prepared to proceed with depositions of the parties next week. More importantly, Centennial does not belong in the
case and I respectfully request that the Court consider our motion papers before setting a new date.
The Court has our thanks for its attention to this matter.
Best Regards,
Sasha Robins
Babchik & Young, LLP
245 Main Street, Suite 330
White Plains, NY 10601
Tel : 914. 4.70-0001 x 31
Fax : 914 470-0009
Cell: 914 208-6812
e-mail : sasha.robins@babchikyoung.com
From: Susan Stromberg
Sent: Wednesday, September 15, 2021 2:06 PM
To: sfc-part23@nycourts.gov
Cc: Dominika Szybisty ; Anne Amatulli ; Brett Nomberg
; Sasha Robins
Subject: RE: Conference requested - Itara v. Masaryk,, et al Index # 152948/2020
We represent defendant/third-party plaintiff Masaryk Towers Corporation. We are in receipt of Plaintiff's
letter to the Court of today's date. While we object to, and disagree with, the contents of Plaintiff's letter, we
agree that a court conference is required to work out the issues with regard to the upcoming depositions in
this case, the first of which is scheduled for Tuesday, September 21.
I will be out of the office this afternoon and tomorrow for religious observance. I will be returning to the
office on Friday, September 17, 2021. As such, it is respectfully requested that if a conference is scheduled,
that it be held on Friday, September 17, 2021.
4
FILED: NEW YORK COUNTY CLERK 11/03/2021 05:54 PM INDEX NO. 152948/2020
NYSCEF DOC. NO. 157 RECEIVED NYSCEF: 11/03/2021
The Court's time and attention to this matter is greatly appreciated.
Respectfully submitted,
Susan J. Stromberg
Susan J. Stmmberg, Esq.
Partner
............................................
MMPaS
Milber Makris Plousadis & Seiden, LLP
1000 Woodbury Road, Suite 402
Woodbury, New York 11797
516.712.4000 ext.1103
516.870.1103 direct
516.712.4013 fax
sstromberq@milbermakris.com
1his electrome mail transmission is privileged and confidential and is intended only for the review of the party to whom it is addressed. If you have received this
transmission in error. please immediately retum it to the sender. Unintended transmission shall not constitute waiver of the attomey-client or any other privilege
For more inforrnation about MMP&S. please visit www.milbermakris.ççm.
From: Brett Nomberg
Sent: Wednesday, September 15, 202111:51 AM
To: sfc-part23@nycourts.gov; sasha.robins@babchikyoung.com; Susan Strambêrg
Cc: Dominika Szybisty
Subject: Conference requested - Itara v. Masaryk,, et al Index # 152948/2020
External Sender Detected
This is an external email. Be certain that the message is really from the person it claims to be from (by
clicking on sender's name toverify email address.) Be wary of
any links, login requests, attachments, or
requests for personal or financial information that appear below this advisory.
Please see attached requesting an immediate video court conference.
Brett J. Nomberg
Brand Brand Nomberg & Rosenbaum, LLP
3rd 7th
622 Avenue, FlOOr
New York, NY 10017
(212)808-0448
bnomberg@bbnrlaw.com
www.bbnrlaw.çnm
Confidentiality Notice
----.______________.--------- -----
This email and any files transmitted with it are confidential and intended solely for the use of the
individual or entity to whom they are addressed. If you are not the intended addressee, then you are
not permitted to disseminate, distiibute or copy any medical infonnation, dates of birth, or Social
5
FILED: NEW YORK COUNTY CLERK 11/03/2021 05:54 PM INDEX NO. 152948/2020
NYSCEF DOC. NO. 157 RECEIVED NYSCEF: 11/03/2021
Security numbers, or any other private information of such nature. Please notify the sender
immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your
system. If you a e not the intended recipient you are notified that disclosing, copying,distributing or
taking any action in reliance on the contents of this information is strictly prohibited. Confidential
health information is protected by state and federal law, including, but not |imited to, by the Health
Insurance Portability and Accountability Act of 1996 and related regulations.
Please be CAREFUL when clicking links or opening attachments from external senders.
6
Preview
FILED: NEW YORK COUNTY CLERK 11/03/2021 05:54 PM INDEX NO. 152948/2020 NYSCEF DOC. NO. 157 RECEIVED NYSCEF: 11/03/2021 EXHIBIT “R” EXHIBIT “R” FILED: NEW YORK COUNTY CLERK 11/03/2021 05:54 PM INDEX NO. 152948/2020 NYSCEF DOC. NO. 157 RECEIVED NYSCEF: 11/03/2021 From: Susan Stromberg Sent: Friday, September 17, 2021 6:13 PM To: Brett Nomberg; SFC-PART23; Sasha Robins Szybisty· Cc: Dominika Anne Amatulli; Hon. Franc W Perry Subject RE: Conference requested - Itara v. Masaryk,, et al Index # 152948/2020 PIs' Pls' - Dr. Attach=ênts: Further Response to Demands for D&l 9.14.2021.PDF; Medical Exchange Steven Touliopoulos.PDF Dear Ms. Cangiano: I am at a loss as to why Plaintiff's counsel continues to harangue the Court with unnecessary emails. I never said that I refused to proceed with depositions unless they were held in person. Plaintiff wrote to the Court requesting depositions via video, I requested them in person, and the issue is before the Court. I am available for a conference call on Monday should the Court deem it necessary. However, an email from the Court with regard to this issue should suffice, and I will abide by the Court's decision. I will, however, take this opportunity to point out Plaintiff's counsel provided my office with a Medical Exchange on September 14, 2021, three days ago, and two additional authorizations to obtain medical records for surgery that Plaintiff apparently underweñt on August 9, 2021. Plaintiff did not provide the authorizations for this surgery until September 14, 2021, more than a month after the surgery, and one week before Plaintiff's scheduled deposition. Should the depositions go forward on September 21, either in person or via video, we will reserve our right to a further deposition of the Plaintiff once the medical records are received pursuant to these new authorizations. Respectfully submitted, Susan J. Stromberg Susan J. Stromberg, Esq. Partner ............................................ MMPaS Milber Makris Plousadis & Seiden, LLP 1000 Woodbury Road, Suite 402 Woodbury, New York 11797 516.712.4000 ext.1103 516.870.1103 direct 516.712.4013 fax sstromberq(Amilbermakris.corn This electronic mail transmission is privileged and confidential and is intended only for the review of the party to whom it is addressed. If you have received this transmission in error, please immediately retum it to the sender. Unintended transmission shall not constitute waiver of the attomey-client or any other privilege For more information about MMP&S, please visit www.milbermakris.com. From: Brett Nomberg Sent: Friday, September 17, 2021 5:56 PM To: SFC-PART23 ; Sasha Robins Cc: Dominika Szybisty ; Anne Amatulli ; Susan Stromberg 1 FILED: NEW YORK COUNTY CLERK 11/03/2021 05:54 PM INDEX NO. 152948/2020 NYSCEF DOC. NO. 157 RECEIVED NYSCEF: 11/03/2021 ; Hon. Franc W Perry Subject: RE: Conference requested - itara v. Masaryk,, et al Index # 152948/2020 External Sender Dete_cted This is an external email. Be certain that the message is really from the person it claims to be from (by clicking on sender's name to verify email address.) Be wary ofany links, login requests, attachments, or requests for personal or financial information that appear below this advisory. Ms. Cangiano, in light of defense counsel's refusal now to proceed with the depositions scheduled for Tuesday unless in person, as well as the other issues that could not be resolved, I again request, in compliance with the part rules, a conference call/video for Monday morning with the court. Below is defense counsel's email in April giving no reason to believe she would have any issue if we did not want to proceed in person. Since that time we have learned that even being vaccinated does not mean a person is not infected and contagious with the Delta variant. From: Susan Stromberg Sent: Wednesday, April 28, 2021 4:00 PM To: Dominika Szybisty ; Brett Nomberg subject: RE: Itara My client is available on June 17, 2021for his deposition. I have your client down for June 16. Brett, we can discuss if these will be in person or virtual. I am very sensitive to this issue, and I do not want to make anyone feel uncomfortable. Let's table this decision until the date gets closer, and we can see where we are with vaccinations and people's comfort levels. Thanks, Susan Susan J. Stromberg, Esq. Partner ............................................ MMP&S MilberMakris Plousadis & Seiden, LLP 1000 Woodbury Road, Suite 402 Woodbury, New York 11797 516.712.4000 ext.1103 516.870.1103 direct 516.712.4013 fax sstromberg@milbermakris.com Respectfully, Brett J. Nomberg Brand Brand Nomberg & Rosenbaum, LLP 3d 7th 622 Avenue, Floor New York, NY 10017 (212)808-0448 bnomberg@bbnrlaw.com www.bbnrlaw.çqm 2 FILED: NEW YORK COUNTY CLERK 11/03/2021 05:54 PM INDEX NO. 152948/2020 NYSCEF DOC. NO. 157 RECEIVED NYSCEF: 11/03/2021 Notice -- Confidentiality ------------- ---- This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you are not the intended addressee, then you are not permitted to disseminate, distribute or copy any medical information, dates of birth, or Social Security numbers, or any other private information of such nature. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. If you are not the intended recipient you are notified that disclosing, copying,distributing or taking any action in reliance on the contents of this information is strictly prohibited. Confidential health information is protected by state and federal law, including, but not limited to, by the Health Insurance Portability and Accountability Act of 1996 and related regulations. From: SFC-PART23 Sent: Friday, September 17, 2021 10:31 AM To: Sasha Robins ; SFC-PART23 Cc: Dominika Szybisty ; Anne Amatulli ; Brett Norñberg ; Susan Stromberg ; Hon. Franc W Perry Subject: RE: Conference requested - Itara v. Masaryk,, et al Index # 152948/2020 Good morning counsel: Justice Perry directs the parties to meet and confer to resolve the issue related to plaintiff's deposition presently scheduled for September 21, 2021, in accordance with Uniform Rule Section 202.20-f (b) Disclosure Disputes, which provides in pertinent part, "Absent exigent circumstances, prior to contacting the court regarding a disclosure dispute, counsel must first consult with one another in a good faith effort to resolve all disputes about conference." disclosure. Such consultation must take place by an in-person or telephonic In addition, please note that plaintiff's motion sequence number 002 and the defendant's cross motion, were filed in violation of the above quoted rule and in violation of Justice Perry's Part Rules. Accordingly, the parties are directed to meet and confer, in good faith, in order to resolve the discovery issues including scheduling depositions, given that the third party defendant has recently appeared in this matter by filing a pre- answer motion to dismiss which is returnable in Room 130 on October 4, 2021. In the event that the parties cannot resolve this discovery dispute following good faith consultation and withdraw the pending discovery motions, the court notes that there is already a remote compliance conference scheduled in this matter on October 6, 2021 at 9:30. Alternatively, in lieu of appearing at the October 6 remote conference, the parties are encouraged to resolve the issues and set forth new dates for any outstanding discovery and schedule dates for depositions. Attached please find a blank Compliance Conference Order which can be submitted to the Court for review and signature, in lieu of attending the October 6 remote conference. Or, given the motion to dismiss, the parties may opt to adjourn the remote compliance pending conference. Finally, during these very trying times when we are all experiencing delays and other issues from the pandemic, the parties are reminded of the importance of professional courtesy and resulting cooperation when dealing with one another. Please advise the Court how you wish to proceed. 3 FILED: NEW YORK COUNTY CLERK 11/03/2021 05:54 PM INDEX NO. 152948/2020 NYSCEF DOC. NO. 157 RECEIVED NYSCEF: 11/03/2021 Nina Cangiano Principal Law Clerk to the Hon. W. Franc Perry Supreme Court of the State of New York 80 Centre Street-Room 307 New York, New York 10013 From: Sasha Robins [mailto:sasha.robins@babchikyoung.coml Sent: Wednesday, September 15, 2021 5:40 PM To: SFC-PART23 Cc: Dominika Szybisty ; Anne Amatulli ; Brett NGmbêig ; Susan Stromberg Subject: RE: Conference requested - Itara v. et at Index # 152948/2020 Masaryk,, Dear Justice Perry: We represent Third-Party Defendant Centennial Elevator Industries, Plaintiff's employer. I would also appreciate a brief conference with the Court. As can be seen by my motion to dismiss, I have just appeared in the action, and would not be prepared to proceed with depositions of the parties next week. More importantly, Centennial does not belong in the case and I respectfully request that the Court consider our motion papers before setting a new date. The Court has our thanks for its attention to this matter. Best Regards, Sasha Robins Babchik & Young, LLP 245 Main Street, Suite 330 White Plains, NY 10601 Tel : 914. 4.70-0001 x 31 Fax : 914 470-0009 Cell: 914 208-6812 e-mail : sasha.robins@babchikyoung.com From: Susan Stromberg Sent: Wednesday, September 15, 2021 2:06 PM To: sfc-part23@nycourts.gov Cc: Dominika Szybisty ; Anne Amatulli ; Brett Nomberg ; Sasha Robins Subject: RE: Conference requested - Itara v. Masaryk,, et al Index # 152948/2020 We represent defendant/third-party plaintiff Masaryk Towers Corporation. We are in receipt of Plaintiff's letter to the Court of today's date. While we object to, and disagree with, the contents of Plaintiff's letter, we agree that a court conference is required to work out the issues with regard to the upcoming depositions in this case, the first of which is scheduled for Tuesday, September 21. I will be out of the office this afternoon and tomorrow for religious observance. I will be returning to the office on Friday, September 17, 2021. As such, it is respectfully requested that if a conference is scheduled, that it be held on Friday, September 17, 2021. 4 FILED: NEW YORK COUNTY CLERK 11/03/2021 05:54 PM INDEX NO. 152948/2020 NYSCEF DOC. NO. 157 RECEIVED NYSCEF: 11/03/2021 The Court's time and attention to this matter is greatly appreciated. Respectfully submitted, Susan J. Stromberg Susan J. Stmmberg, Esq. Partner ............................................ MMPaS Milber Makris Plousadis & Seiden, LLP 1000 Woodbury Road, Suite 402 Woodbury, New York 11797 516.712.4000 ext.1103 516.870.1103 direct 516.712.4013 fax sstromberq@milbermakris.com 1his electrome mail transmission is privileged and confidential and is intended only for the review of the party to whom it is addressed. If you have received this transmission in error. please immediately retum it to the sender. Unintended transmission shall not constitute waiver of the attomey-client or any other privilege For more inforrnation about MMP&S. please visit www.milbermakris.ççm. From: Brett Nomberg Sent: Wednesday, September 15, 202111:51 AM To: sfc-part23@nycourts.gov; sasha.robins@babchikyoung.com; Susan Strambêrg Cc: Dominika Szybisty Subject: Conference requested - Itara v. Masaryk,, et al Index # 152948/2020 External Sender Detected This is an external email. Be certain that the message is really from the person it claims to be from (by clicking on sender's name toverify email address.) Be wary of any links, login requests, attachments, or requests for personal or financial information that appear below this advisory. Please see attached requesting an immediate video court conference. Brett J. Nomberg Brand Brand Nomberg & Rosenbaum, LLP 3rd 7th 622 Avenue, FlOOr New York, NY 10017 (212)808-0448 bnomberg@bbnrlaw.com www.bbnrlaw.çnm Confidentiality Notice ----.______________.--------- ----- This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you are not the intended addressee, then you are not permitted to disseminate, distiibute or copy any medical infonnation, dates of birth, or Social 5 FILED: NEW YORK COUNTY CLERK 11/03/2021 05:54 PM INDEX NO. 152948/2020 NYSCEF DOC. NO. 157 RECEIVED NYSCEF: 11/03/2021 Security numbers, or any other private information of such nature. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. If you a e not the intended recipient you are notified that disclosing, copying,distributing or taking any action in reliance on the contents of this information is strictly prohibited. Confidential health information is protected by state and federal law, including, but not |imited to, by the Health Insurance Portability and Accountability Act of 1996 and related regulations. Please be CAREFUL when clicking links or opening attachments from external senders. 6