On January 20, 2023 a
EXHIBIT(S) - G - 1/4/24 Email
was filed
involving a dispute between
F James Mcguire,
and
The Mcguire Group,
for Commercial Division
in the District Court of Erie County.
Preview
FILED: ERIE COUNTY CLERK 01/12/2024 05:35 PM INDEX NO. 801061/2023
NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 01/12/2024
EXHIBIT G
FILED: ERIE COUNTY CLERK 01/12/2024 05:35 PM INDEX NO. 801061/2023
NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 01/12/2024
Archived: Wednesday, January 10, 2024 12:33:49 PM
From: Horn, John
Mail received time: Thu, 4 Jan 2024 12:16:23
Sent: Thu, 4 Jan 2024 17:16:21
To: Horn, John David Fryman
Cc: Mendolera, Lauren R.
Subject: RE: McGuire v. TMG: Conference Follow-up [HSELAW-WORKSITE.FID972155]
Importance: Normal
Sensitivity: None
David,
At the conclusion of our court conference 24 days ago, Justice Colaiacovo said, “I don’t want to sound like a broken record, but
get Mr. Horn what he’s looking for.”
I sent you the note below within two hours of his making that remark and have neither heard nor received anything from you
in response.
Please furnish your client’s complete document production by Monday, January 8, 2024, or I will be left with no option but to
contact the Court.
Thank you.
John
John G. Horn, Partner
he/him/his
Harter Secrest & Emery LLP
50 Fountain Plaza, Suite 1000, Buffalo, NY 14202-2293
O: 716.844.3728 | F: 716.853.1617
jhorn@hselaw.com | Bio | vCard
Rochester | Buffalo | Albany | Corning | New York City
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This e-mail message is from a law firm and may contain information that is privileged or confidential. It is not intended for
transmission to, or receipt by, any unauthorized persons. If you have received this electronic mail transmission in error, do
not read it. Please delete it from your system without copying it, and notify the sender by reply e-mail at jhorn@hselaw.com
or by calling 716.844.3728, so that our address record can be corrected.
From: Horn, John
Sent: Monday, December 11, 2023 12:23 PM
To: David Fryman
FILED: ERIE COUNTY CLERK 01/12/2024 05:35 PM INDEX NO. 801061/2023
NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 01/12/2024
Cc: Mendolera, Lauren R.
Subject: McGuire v. TMG: Conference Follow-up [HSELAW-WORKSITE.FID972155]
David,
Please advise as to when we may expect your client’s overdue document production.
Thank you.
John
John G. Horn, Partner
he/him/his
Harter Secrest & Emery LLP
50 Fountain Plaza, Suite 1000, Buffalo, NY 14202-2293
O: 716.844.3728 | F: 716.853.1617
jhorn@hselaw.com | Bio | vCard
Rochester | Buffalo | Albany | Corning | New York City
Subscribe to HSE Content and Learn about HSE’s Online Training
Program
This e-mail message is from a law firm and may contain information that is privileged or confidential. It is not intended for
transmission to, or receipt by, any unauthorized persons. If you have received this electronic mail transmission in error, do
not read it. Please delete it from your system without copying it, and notify the sender by reply e-mail at jhorn@hselaw.com
or by calling 716.844.3728, so that our address record can be corrected.
Document Filed Date
January 12, 2024
Case Filing Date
January 20, 2023
Category
Commercial Division
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Preview
FILED: ERIE COUNTY CLERK 01/12/2024 05:35 PM INDEX NO. 801061/2023 NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 01/12/2024 EXHIBIT G FILED: ERIE COUNTY CLERK 01/12/2024 05:35 PM INDEX NO. 801061/2023 NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 01/12/2024 Archived: Wednesday, January 10, 2024 12:33:49 PM From: Horn, John Mail received time: Thu, 4 Jan 2024 12:16:23 Sent: Thu, 4 Jan 2024 17:16:21 To: Horn, John David Fryman Cc: Mendolera, Lauren R. Subject: RE: McGuire v. TMG: Conference Follow-up [HSELAW-WORKSITE.FID972155] Importance: Normal Sensitivity: None David, At the conclusion of our court conference 24 days ago, Justice Colaiacovo said, “I don’t want to sound like a broken record, but get Mr. Horn what he’s looking for.” I sent you the note below within two hours of his making that remark and have neither heard nor received anything from you in response. Please furnish your client’s complete document production by Monday, January 8, 2024, or I will be left with no option but to contact the Court. Thank you. John John G. Horn, Partner he/him/his Harter Secrest & Emery LLP 50 Fountain Plaza, Suite 1000, Buffalo, NY 14202-2293 O: 716.844.3728 | F: 716.853.1617 jhorn@hselaw.com | Bio | vCard Rochester | Buffalo | Albany | Corning | New York City Subscribe to HSE Content and Learn about HSE’s Online Training Program This e-mail message is from a law firm and may contain information that is privileged or confidential. It is not intended for transmission to, or receipt by, any unauthorized persons. If you have received this electronic mail transmission in error, do not read it. Please delete it from your system without copying it, and notify the sender by reply e-mail at jhorn@hselaw.com or by calling 716.844.3728, so that our address record can be corrected. From: Horn, John Sent: Monday, December 11, 2023 12:23 PM To: David Fryman FILED: ERIE COUNTY CLERK 01/12/2024 05:35 PM INDEX NO. 801061/2023 NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 01/12/2024 Cc: Mendolera, Lauren R. Subject: McGuire v. TMG: Conference Follow-up [HSELAW-WORKSITE.FID972155] David, Please advise as to when we may expect your client’s overdue document production. Thank you. John John G. Horn, Partner he/him/his Harter Secrest & Emery LLP 50 Fountain Plaza, Suite 1000, Buffalo, NY 14202-2293 O: 716.844.3728 | F: 716.853.1617 jhorn@hselaw.com | Bio | vCard Rochester | Buffalo | Albany | Corning | New York City Subscribe to HSE Content and Learn about HSE’s Online Training Program This e-mail message is from a law firm and may contain information that is privileged or confidential. It is not intended for transmission to, or receipt by, any unauthorized persons. If you have received this electronic mail transmission in error, do not read it. Please delete it from your system without copying it, and notify the sender by reply e-mail at jhorn@hselaw.com or by calling 716.844.3728, so that our address record can be corrected.