Preview
FILED: NASSAU COUNTY CLERK 01/30/2024 02:23 PM INDEX NO. 602495/2023
NYSCEF DOC. NO. 47 RECEIVED NYSCEF: 01/30/2024
EXHIBIT G
FILED: NASSAU COUNTY CLERK 01/30/2024 02:23 PM INDEX NO. 602495/2023
NYSCEF DOC. NO. 47 RECEIVED NYSCEF: 01/30/2024
From: Bonura, Maryellen
To: Tara.Fappiano@hbandglaw.com; joseph.fanning@hbandglaw.com; jmolloy@mcwpc.com; BISOGNO &
MEYERSON LLP; Elizabeth.kimundi@hbandglaw.com; jmccartney@mcwpc.com
Cc: Smith, David C; Myrick, Gail
Subject: RE: RE: 602495/2023 Roy Rachpaul v. New York State Urban Development Corporation et al
Date: Tuesday, January 23, 2024 1:52:00 PM
Attachments: Rachpaul Partial Stipulation of Discontinuance.pdf
Good afternoon,
I am just following up on the below email regarding the attached Partial Stipulation of
Discontinuance.
Thank you for your courtesy and cooperation.
Sincerely,
Maryellen
Secretary to David Smith
Maryellen Bonura
Legal Secretary
Martyn, Smith, Murray & Yong
Liberty Mutual Staff Counsel Legal Services, Employees of Liberty Mutual Group, Inc.
Physical Address:
102 Motor Parkway, Suite 230
Hauppauge, New York 11788
Please serve all documents on MMSMLaw@libertymutual.com
Direct Number (516) 247-3067
Direct Fax (603) 334-7302
Mailing Address:
P.O. Box 6835
Scranton, PA 18505-6835
This e-mail and any attachments thereto, is intended only for the use of the addressee(s) named herein and may contain
legally privileged and/or confidential information. If you are not the intended recipient of this e-mail, you are hereby
notified that any dissemination, distribution or copying of this e-mail, and any attachments thereto, is strictly prohibited.
If you have received this e-mail in error, please notify me via return e-mail and via telephone at 516-739-0000 and
permanently delete the original and any copy of any e-mail and any printout thereof. Please be advised that there is a
risk a third party can gain access when sending or receiving electronic communications using a computer or other
device, or e-mail account.
From: Bonura, Maryellen
Sent: Friday, January 12, 2024 1:10 PM
To: Tara.Fappiano@hbandglaw.com; joseph.fanning@hbandglaw.com; jmolloy@mcwpc.com;
BISOGNO & MEYERSON LLP ; Elizabeth.kimundi@hbandglaw.com;
jmccartney@mcwpc.com
Cc: Smith, David C
Subject: RE: 602495/2023 Roy Rachpaul v. New York State Urban Development Corporation et al
FILED: NASSAU COUNTY CLERK 01/30/2024 02:23 PM INDEX NO. 602495/2023
NYSCEF DOC. NO. 47 RECEIVED NYSCEF: 01/30/2024
Good afternoon,
Attached please find a Partial Stipulation of Discontinuance as to New York State Urban
Development Corporation d/b/a Empire State Development in the above matter. If agreed, please
sign the attached stipulation return via email. The attorney handling this matter is David Smith.
Thank you for your cooperation in this matter.
Maryellen
Secretary to David Smith
Maryellen Bonura
Legal Secretary
Martyn, Smith, Murray & Yong
Liberty Mutual Staff Counsel Legal Services, Employees of Liberty Mutual Group, Inc.
Physical Address:
102 Motor Parkway, Suite 230
Hauppauge, New York 11788
Please serve all documents on MMSMLaw@libertymutual.com
Direct Number (516) 247-3067
Direct Fax (603) 334-7302
Mailing Address:
P.O. Box 6835
Scranton, PA 18505-6835
This e-mail and any attachments thereto, is intended only for the use of the addressee(s) named herein and may contain
legally privileged and/or confidential information. If you are not the intended recipient of this e-mail, you are hereby
notified that any dissemination, distribution or copying of this e-mail, and any attachments thereto, is strictly prohibited.
If you have received this e-mail in error, please notify me via return e-mail and via telephone at 516-739-0000 and
permanently delete the original and any copy of any e-mail and any printout thereof. Please be advised that there is a
risk a third party can gain access when sending or receiving electronic communications using a computer or other
device, or e-mail account.
FILED: NASSAU COUNTY CLERK 01/30/2024 02:23 PM INDEX NO. 602495/2023
NYSCEF DOC. NO. 47 RECEIVED NYSCEF: 01/30/2024
DCS/gm 602495/23
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
------------------------------------------------------------------X
ROY RACHPAUL,
Plaintiff,
-against-
STIPULATION OF PARTIAL
NEW YORK STATE URBAN DEVELOPMENT DISCONTINUANCE
CORPORATION D/B/A EMPIRE STATE
DEVELOPMENT; NEW YORK ARENA PARTNERS, Index No. 602495/23
LLC.; UBS ARENA D/B/A UBS ARENA
FOUNDATION, INC.; and ATHLETICA SPORTS
SYSTEMS, INC.,
Defendants.
------------------------------------------------------------------X
IT IS HEREBY STIPULATED AND AGREED, by and between the attorneys for the
respective parties hereto, that the above entitled action be, and the same hereby is, discontinued
with prejudice as to NEW YORK STATE URBAN DEVELOPMENT CORPORATION d/b/a
EMPIRE STATE DEVELOPMENT only and without costs to either party as against the other.
This Stipulation may be filed without further notice with the Clerk of the Court.
Dated: Hauppauge, New York
December 27, 2023
_____________________________________ _____________________________________
By: By: David C. Smith
BISOGNO & MEYERSON, LLP MARTYN, SMITH, MURRAY and YONG
Attorneys for Plaintiff Attorneys for Defendant
7018 Fort Hamilton Parkway NEW YORK STATE URBAN
Brooklyn, New York 11228 DEVELOPMENT CORPORATION d/b/a
(718) 745-0880 EMPIRE STATE DEVELOPMENT
102 Motor Parkway, Suite 230
Hauppauge, New York 11788
(516) 739-0000
FILED: NASSAU COUNTY CLERK 01/30/2024 02:23 PM INDEX NO. 602495/2023
NYSCEF DOC. NO. 47 RECEIVED NYSCEF: 01/30/2024
_____________________________________ _____________________________________
By: By:
MARSHALL, CONWAY, BRADLEY, HAWORTH BARBER & GERSTMAN,
GOLLUB & WEISSMAN, P.C. LLC
Attorneys for Defendant Attorneys for Defendant
NEW YORK ARENA PARTNERS, LLC ATHLETICA SPORTS SYSTEMS, INC.
45 Broadway, Suite 740 777 Third Avenue, Suite 2104
New York, NY 10006 New York, NY 10017
(212) 619-4444 (212) 952-1100
Preview
FILED: NASSAU COUNTY CLERK 01/30/2024 02:23 PM INDEX NO. 602495/2023 NYSCEF DOC. NO. 47 RECEIVED NYSCEF: 01/30/2024 EXHIBIT G FILED: NASSAU COUNTY CLERK 01/30/2024 02:23 PM INDEX NO. 602495/2023 NYSCEF DOC. NO. 47 RECEIVED NYSCEF: 01/30/2024 From: Bonura, Maryellen To: Tara.Fappiano@hbandglaw.com; joseph.fanning@hbandglaw.com; jmolloy@mcwpc.com; BISOGNO & MEYERSON LLP; Elizabeth.kimundi@hbandglaw.com; jmccartney@mcwpc.com Cc: Smith, David C; Myrick, Gail Subject: RE: RE: 602495/2023 Roy Rachpaul v. New York State Urban Development Corporation et al Date: Tuesday, January 23, 2024 1:52:00 PM Attachments: Rachpaul Partial Stipulation of Discontinuance.pdf Good afternoon, I am just following up on the below email regarding the attached Partial Stipulation of Discontinuance. Thank you for your courtesy and cooperation. Sincerely, Maryellen Secretary to David Smith Maryellen Bonura Legal Secretary Martyn, Smith, Murray & Yong Liberty Mutual Staff Counsel Legal Services, Employees of Liberty Mutual Group, Inc. Physical Address: 102 Motor Parkway, Suite 230 Hauppauge, New York 11788 Please serve all documents on MMSMLaw@libertymutual.com Direct Number (516) 247-3067 Direct Fax (603) 334-7302 Mailing Address: P.O. Box 6835 Scranton, PA 18505-6835 This e-mail and any attachments thereto, is intended only for the use of the addressee(s) named herein and may contain legally privileged and/or confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please notify me via return e-mail and via telephone at 516-739-0000 and permanently delete the original and any copy of any e-mail and any printout thereof. Please be advised that there is a risk a third party can gain access when sending or receiving electronic communications using a computer or other device, or e-mail account. From: Bonura, Maryellen Sent: Friday, January 12, 2024 1:10 PM To: Tara.Fappiano@hbandglaw.com; joseph.fanning@hbandglaw.com; jmolloy@mcwpc.com; BISOGNO & MEYERSON LLP ; Elizabeth.kimundi@hbandglaw.com; jmccartney@mcwpc.com Cc: Smith, David C Subject: RE: 602495/2023 Roy Rachpaul v. New York State Urban Development Corporation et al FILED: NASSAU COUNTY CLERK 01/30/2024 02:23 PM INDEX NO. 602495/2023 NYSCEF DOC. NO. 47 RECEIVED NYSCEF: 01/30/2024 Good afternoon, Attached please find a Partial Stipulation of Discontinuance as to New York State Urban Development Corporation d/b/a Empire State Development in the above matter. If agreed, please sign the attached stipulation return via email. The attorney handling this matter is David Smith. Thank you for your cooperation in this matter. Maryellen Secretary to David Smith Maryellen Bonura Legal Secretary Martyn, Smith, Murray & Yong Liberty Mutual Staff Counsel Legal Services, Employees of Liberty Mutual Group, Inc. Physical Address: 102 Motor Parkway, Suite 230 Hauppauge, New York 11788 Please serve all documents on MMSMLaw@libertymutual.com Direct Number (516) 247-3067 Direct Fax (603) 334-7302 Mailing Address: P.O. Box 6835 Scranton, PA 18505-6835 This e-mail and any attachments thereto, is intended only for the use of the addressee(s) named herein and may contain legally privileged and/or confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please notify me via return e-mail and via telephone at 516-739-0000 and permanently delete the original and any copy of any e-mail and any printout thereof. Please be advised that there is a risk a third party can gain access when sending or receiving electronic communications using a computer or other device, or e-mail account. FILED: NASSAU COUNTY CLERK 01/30/2024 02:23 PM INDEX NO. 602495/2023 NYSCEF DOC. NO. 47 RECEIVED NYSCEF: 01/30/2024 DCS/gm 602495/23 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU ------------------------------------------------------------------X ROY RACHPAUL, Plaintiff, -against- STIPULATION OF PARTIAL NEW YORK STATE URBAN DEVELOPMENT DISCONTINUANCE CORPORATION D/B/A EMPIRE STATE DEVELOPMENT; NEW YORK ARENA PARTNERS, Index No. 602495/23 LLC.; UBS ARENA D/B/A UBS ARENA FOUNDATION, INC.; and ATHLETICA SPORTS SYSTEMS, INC., Defendants. ------------------------------------------------------------------X IT IS HEREBY STIPULATED AND AGREED, by and between the attorneys for the respective parties hereto, that the above entitled action be, and the same hereby is, discontinued with prejudice as to NEW YORK STATE URBAN DEVELOPMENT CORPORATION d/b/a EMPIRE STATE DEVELOPMENT only and without costs to either party as against the other. This Stipulation may be filed without further notice with the Clerk of the Court. Dated: Hauppauge, New York December 27, 2023 _____________________________________ _____________________________________ By: By: David C. Smith BISOGNO & MEYERSON, LLP MARTYN, SMITH, MURRAY and YONG Attorneys for Plaintiff Attorneys for Defendant 7018 Fort Hamilton Parkway NEW YORK STATE URBAN Brooklyn, New York 11228 DEVELOPMENT CORPORATION d/b/a (718) 745-0880 EMPIRE STATE DEVELOPMENT 102 Motor Parkway, Suite 230 Hauppauge, New York 11788 (516) 739-0000 FILED: NASSAU COUNTY CLERK 01/30/2024 02:23 PM INDEX NO. 602495/2023 NYSCEF DOC. NO. 47 RECEIVED NYSCEF: 01/30/2024 _____________________________________ _____________________________________ By: By: MARSHALL, CONWAY, BRADLEY, HAWORTH BARBER & GERSTMAN, GOLLUB & WEISSMAN, P.C. LLC Attorneys for Defendant Attorneys for Defendant NEW YORK ARENA PARTNERS, LLC ATHLETICA SPORTS SYSTEMS, INC. 45 Broadway, Suite 740 777 Third Avenue, Suite 2104 New York, NY 10006 New York, NY 10017 (212) 619-4444 (212) 952-1100