On May 08, 2023 a
Letter,Correspondence
was filed
involving a dispute between
David Adames,
and
A. Duie Pyle, Inc.,
Michael Edward Martin,
for Torts - Motor Vehicle
in the District Court of Bronx County.
Preview
FILED: BRONX COUNTY CLERK 01/11/2024 01:00 PM INDEX NO. 807199/2023E
NYSCEF DOC. NO. 16 RECEIVED eeplaw.com
NYSCEF: 385
80 Pine
01/11/2024
Floor Street,
New York, New York 10005
T. 212.532.1116F. 212.532.1176
JOHN ELEFTERAKIS*
NICHOLASELEFTERAKIS
RAYMONDPANEK
OLIVER R. TOBIAS+
ELEFTERAKIS JEFFREYB. BROMFELD
2AABÊeE TRVIS
ELEFTERAKIS E
STEPHENB. KAHN
& PANEK
JOHNSONATKINSON
ElLEEN KAPLAN
I
MARK NEWMAN
WAYNE WATTLEY
GENNAROSAVASTANO
RYAN AMATO
DAVID A. BONlLLA
UDEYVEERBRAR
DANIELBROCCO
2024 SAMANTHAMARIA CHASE
January 10,
ANDREY DEMIDOV
TAYLOR FRIEDMAN^
MICHAELGLUCK
CHIARA INGHIRAMl
ANDREWLEVINSON
Via electronic MELISSAN. MAGlLL
filing
SOBEL PEVZNER, LLC JEVAM CHAEL
464 New York Suite 100 ZACHARYMONTANEZ
Avenue, NICASIO*
GINA
Huntington, New York 11743 AGGELlKI E. NIKOLAIDIS
JOSEPH PERRY
PRIOLO*
MARIE LOUISE
Re: DAVID ADAMES v. MICHAEL EDWARD MARTIN, et. al. pHILIP A. SCHULTZE
Index No.: 807199/2023E DAVID SULLIVAN
KEYONTESUTHERLAND
MATT SWANSEN*
Dear Counselor(s): JOJU THOMAS
VANNELLA*
BRIAN
As you are aware, this office represents Plaintiff in the above-referenced
nui PINCZEWSKl
matter. Be advised, to date, we have not received a response to Plaintiff's Demand DEVON REIFF
a Verified Bill of Notice and EVAN M.La PENNA
for Particulars, for Discovery Inspection, Combined
Demands and Demand for each dated November 2023. Please * Also AdmittedIn New
Inspection, 14, Jersey
provide Plaintiff with responses to the discovery, f Also Admitted in Florida
outstanding ^ Also Admitted in Texas
The time to provide responses has now elapsed. Please provide complete responses upon
receipt of this correspondence.
Kindly provide a response to the aforementioned demands within the next seven (7) days
to avoid the necessity of judicial intervention. Please be advised that, should you fail to provide
the subject discovery responses within the aforementioned time period, Plaintiff will use the instant
letter as evidence of a good faith attempt to obtain the subject discovery pursuant to 22 NYCRR §
202.7. Moreover, pursuant to Uniform Civil Rule § 202.20-f, titled Disclosure Disputes, please
contact the undersigned to schedule a phone conference within the next three (3) days to discuss
these issues of outstanding discovery, in order to avoid motion practice. Please be advised that the
unreasonable failure or refusal of counsel to participate in a conference requested by another party
may relieve the requesting party of the obligation to comply with the terms of § 202.20-f(b) and
may be addressed by the imposition of sanctions pursuant to Part 130.
1 of 2
FILED: BRONX COUNTY CLERK 01/11/2024 01:00 PM INDEX NO. 807199/2023E
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 01/11/2024
Thank you for your attention to this matter. Should you have questions, please do not
any
hesitate to contact the undersigned.
V trul your
eyveer Singh .
2 of 2
Document Filed Date
January 11, 2024
Case Filing Date
May 08, 2023
Category
Torts - Motor Vehicle
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Preview
FILED: BRONX COUNTY CLERK 01/11/2024 01:00 PM INDEX NO. 807199/2023E NYSCEF DOC. NO. 16 RECEIVED eeplaw.com NYSCEF: 385 80 Pine 01/11/2024 Floor Street, New York, New York 10005 T. 212.532.1116F. 212.532.1176 JOHN ELEFTERAKIS* NICHOLASELEFTERAKIS RAYMONDPANEK OLIVER R. TOBIAS+ ELEFTERAKIS JEFFREYB. BROMFELD 2AABÊeE TRVIS ELEFTERAKIS E STEPHENB. KAHN & PANEK JOHNSONATKINSON ElLEEN KAPLAN I MARK NEWMAN WAYNE WATTLEY GENNAROSAVASTANO RYAN AMATO DAVID A. BONlLLA UDEYVEERBRAR DANIELBROCCO 2024 SAMANTHAMARIA CHASE January 10, ANDREY DEMIDOV TAYLOR FRIEDMAN^ MICHAELGLUCK CHIARA INGHIRAMl ANDREWLEVINSON Via electronic MELISSAN. MAGlLL filing SOBEL PEVZNER, LLC JEVAM CHAEL 464 New York Suite 100 ZACHARYMONTANEZ Avenue, NICASIO* GINA Huntington, New York 11743 AGGELlKI E. NIKOLAIDIS JOSEPH PERRY PRIOLO* MARIE LOUISE Re: DAVID ADAMES v. MICHAEL EDWARD MARTIN, et. al. pHILIP A. SCHULTZE Index No.: 807199/2023E DAVID SULLIVAN KEYONTESUTHERLAND MATT SWANSEN* Dear Counselor(s): JOJU THOMAS VANNELLA* BRIAN As you are aware, this office represents Plaintiff in the above-referenced nui PINCZEWSKl matter. Be advised, to date, we have not received a response to Plaintiff's Demand DEVON REIFF a Verified Bill of Notice and EVAN M.La PENNA for Particulars, for Discovery Inspection, Combined Demands and Demand for each dated November 2023. Please * Also AdmittedIn New Inspection, 14, Jersey provide Plaintiff with responses to the discovery, f Also Admitted in Florida outstanding ^ Also Admitted in Texas The time to provide responses has now elapsed. Please provide complete responses upon receipt of this correspondence. Kindly provide a response to the aforementioned demands within the next seven (7) days to avoid the necessity of judicial intervention. Please be advised that, should you fail to provide the subject discovery responses within the aforementioned time period, Plaintiff will use the instant letter as evidence of a good faith attempt to obtain the subject discovery pursuant to 22 NYCRR § 202.7. Moreover, pursuant to Uniform Civil Rule § 202.20-f, titled Disclosure Disputes, please contact the undersigned to schedule a phone conference within the next three (3) days to discuss these issues of outstanding discovery, in order to avoid motion practice. Please be advised that the unreasonable failure or refusal of counsel to participate in a conference requested by another party may relieve the requesting party of the obligation to comply with the terms of § 202.20-f(b) and may be addressed by the imposition of sanctions pursuant to Part 130. 1 of 2 FILED: BRONX COUNTY CLERK 01/11/2024 01:00 PM INDEX NO. 807199/2023E NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 01/11/2024 Thank you for your attention to this matter. Should you have questions, please do not any hesitate to contact the undersigned. V trul your eyveer Singh . 2 of 2