On December 21, 2020 a
Exhibit,Appendix
was filed
involving a dispute between
Fayetteville Family Denistry Pllc,
Imadeh Nosegbe Dmd,
and
Fayettesmiles Denistry Pllc,
Keybrytem Llc,
Kimber Cummings,
Wayne Cummings,
Zogbam Llc,
for Commercial - Contract
in the District Court of Onondaga County.
Preview
iD: ONONDA PK WV INDEX NO. 007348/2020
OUN 0:0
NYSCEF BOC. NO. 188 RECEIVED NYSCEF: 02/14/2024
EXHIBIT C
iD: ONONDA PK WV INDEX NO. 007348/2020
OUN 0:0
NYSCEF BOC. NO. 188 RECEIVED NYSCEF: 02/14/2024
HARRIS BEACH z
ATTORNEYS AT LAW
Kimber Cummings January 31, 2024
6020 Sneller Road Invoice #8956841
Brewerton, NY 13029
Firm Attorney: James Muldoon Client Name: Kimber Cummings
Firm Matter Numbers: 0066183.320146 Matter Name: Imadeh Nosegbe, Dmd v. Zogbam, LLC, et al.
January Invoice for Statement of Services and Disbursements
ACCOUNT SUMMARY For THIS MATTER
TOTAL FEES THIS INVOICE...
TOTAL AMOUNT DUE FOR THIS INVOICE...
PREVIOUS OUTSTANDING BALANCE FOR THIS MATTER ....
TOTAL AMOUNT DUE FOR THIS MATTER AS OF CURRENT INVOICE (01/31/24).
A late payment penalty .75% per month will be applied to all balances remaining unpaid 30 days
after the invoice date and for each 30 day period thereafter.
iD: ONONDA PK WV INDEX NO. 007348/2020
OUN 0:0
NYSCEF BOC. NO. 188 RECEIVED NYSCEF: 02/14/2024
0066183.320146 Kimber Cummings Harris Beach PLLC
Imadeh Nosegbe, Dmd v. Zogbam, LLC, et al. Invoice # 895684
Page 2
PROFESSIONAL SERVICES RENDERED:
DATE TIMEKEEPER Hours NARRATIVE
12/04/23 BMP 0.70 Draft spoliation motion. Register for oral argument for 4th Dept
appeal case.
12/05/23 BMP 2.10 Draft motion papers in support of motion for spoliation sanctions.
Draft email to J. Muldoon regarding same.
12/07/23 LS 1.40 Research subsequent history of cited cases (good law analysis),
verify quoted sources and review filing for proper citation format in
Memorandum of Law and Notice of Motion.
12/08/23 BMP 0.6 Edit motion for sanctions.
12/08/23 LS 0.20 Continuing research. Research subsequent history of cited cases
(good law analysis), verify quoted sources and review filing for
proper citation format in Memorandum of Law and Notice of
Motion.
12/10/23 JRM 0.50 Work on motions for sanctions.
12/12/23 JRM 1.50 Email communications with client regarding recent checks
deposited in Key bank account of Fayetteville Dental Asso iates.
Researched other dental practices in prior office complex. Office
conference with B. Palfreyman regarding revision of motion for
sanctions. Examined revised draft of motion papers.
12/12/23 BMP 1.61 Edit motion for sanctions. Conferences with J. Muldoon regarding
same. Telephone conference with client and J. Muldoon regarding
same.
12/15/23 JRM 1.10 Email and office conferences regarding finalizing motion for
sanctions. Examined and revised motion papers. Approved for
filing. Wrote client reporting same.
12/15/23 BMP 0.30 Edit and finalize motion for sanctions.
12/15/23 KP 1.50 Finalize Notice of Motion, Memorandum of Law, Attorney
Affirmation and Exhibits and forward to James Muldoon for
review.. 5 file the Motion Papers with the Court; prepare
a. a =
iD: ONONDA PK WV INDEX NO. 007348/2020
OUN 0:0
NYSCEF BOC. NO. 188 RECEIVED NYSCEF: 02/14/2024
0066183.320146 Kimber Cummings Harris Beach PLLC
Imadeh Nosegbe, Dmd v. Zogbam, LLC, et al. Invoice # 895684
Page 3
DATE TIMEKEEPER Hours NARRATIVE
TOTAL HOURS AND FEES
TOTAL AMOUNT DUE FOR THIS INVOICE...
iD: ONONDA PK WV INDEX NO. 007348/2020
OUN 0:0
NYSCEF BOC. NO. 188 RECEIVED NYSCEF: 02/14/2024
HARRIS BEACH z
ATTORNEYS AT LAW
Kimber Cummings January 31, 2024
6020 Sneller Road
Brewerton, NY 13029
Firm Matter Number: 0066183.320146
Invoice #8956841
Firm Attorney: James Muldoon
January Invoice for Statement of Services and Disbursements
TOTAL AMOUNT DUE FOR THIS INVOICE....
PREVIOUS OUTSTANDING BALANCE FOR THIS MATTER...
TOTAL AMOUNT DUE FOR THIS MATTER AS OF CURRENT INVOICE (01/31/24)
A late payment penalty .75% per month will be applied to all balances remaining unpaid 30 days
after the invoice date and for each 30 day period thereafter.
Payment by Credit Card
https://www.harrisbeach.com/payment
Click on link and you will be directed to the Harr Beach Invoice Payment Page.
Please include the Firm Matter Number and Invoice Number which are referenced on this invoice above.
Payment by Wire or ACH
Bank Name: Citizens Bank, Rochester, NY 14604
Account Name: Harris Beach, PLLC Operating A/C
Account 1096
ABA 3103
Swift Code: 1US33
Payment by Check (U.S. Only)
Please include this remittance or print your matter and invoice number (8956841) in the check memo. Mail to:
HARRIS BEACH PLLC
333 West Washington Street, Suite 200
Syracuse, NY 13202
Reference Information
Firm Matter Number: 0066183.320146
Attorney: James Muldoon.
For questions please contact: billing @harrisbeach.com
Federal Tax Id: BEB 836
Document Filed Date
February 14, 2024
Case Filing Date
December 21, 2020
Category
Commercial - Contract
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Preview
iD: ONONDA PK WV INDEX NO. 007348/2020 OUN 0:0 NYSCEF BOC. NO. 188 RECEIVED NYSCEF: 02/14/2024 EXHIBIT C iD: ONONDA PK WV INDEX NO. 007348/2020 OUN 0:0 NYSCEF BOC. NO. 188 RECEIVED NYSCEF: 02/14/2024 HARRIS BEACH z ATTORNEYS AT LAW Kimber Cummings January 31, 2024 6020 Sneller Road Invoice #8956841 Brewerton, NY 13029 Firm Attorney: James Muldoon Client Name: Kimber Cummings Firm Matter Numbers: 0066183.320146 Matter Name: Imadeh Nosegbe, Dmd v. Zogbam, LLC, et al. January Invoice for Statement of Services and Disbursements ACCOUNT SUMMARY For THIS MATTER TOTAL FEES THIS INVOICE... TOTAL AMOUNT DUE FOR THIS INVOICE... PREVIOUS OUTSTANDING BALANCE FOR THIS MATTER .... TOTAL AMOUNT DUE FOR THIS MATTER AS OF CURRENT INVOICE (01/31/24). A late payment penalty .75% per month will be applied to all balances remaining unpaid 30 days after the invoice date and for each 30 day period thereafter. iD: ONONDA PK WV INDEX NO. 007348/2020 OUN 0:0 NYSCEF BOC. NO. 188 RECEIVED NYSCEF: 02/14/2024 0066183.320146 Kimber Cummings Harris Beach PLLC Imadeh Nosegbe, Dmd v. Zogbam, LLC, et al. Invoice # 895684 Page 2 PROFESSIONAL SERVICES RENDERED: DATE TIMEKEEPER Hours NARRATIVE 12/04/23 BMP 0.70 Draft spoliation motion. Register for oral argument for 4th Dept appeal case. 12/05/23 BMP 2.10 Draft motion papers in support of motion for spoliation sanctions. Draft email to J. Muldoon regarding same. 12/07/23 LS 1.40 Research subsequent history of cited cases (good law analysis), verify quoted sources and review filing for proper citation format in Memorandum of Law and Notice of Motion. 12/08/23 BMP 0.6 Edit motion for sanctions. 12/08/23 LS 0.20 Continuing research. Research subsequent history of cited cases (good law analysis), verify quoted sources and review filing for proper citation format in Memorandum of Law and Notice of Motion. 12/10/23 JRM 0.50 Work on motions for sanctions. 12/12/23 JRM 1.50 Email communications with client regarding recent checks deposited in Key bank account of Fayetteville Dental Asso iates. Researched other dental practices in prior office complex. Office conference with B. Palfreyman regarding revision of motion for sanctions. Examined revised draft of motion papers. 12/12/23 BMP 1.61 Edit motion for sanctions. Conferences with J. Muldoon regarding same. Telephone conference with client and J. Muldoon regarding same. 12/15/23 JRM 1.10 Email and office conferences regarding finalizing motion for sanctions. Examined and revised motion papers. Approved for filing. Wrote client reporting same. 12/15/23 BMP 0.30 Edit and finalize motion for sanctions. 12/15/23 KP 1.50 Finalize Notice of Motion, Memorandum of Law, Attorney Affirmation and Exhibits and forward to James Muldoon for review.. 5 file the Motion Papers with the Court; prepare a. a = iD: ONONDA PK WV INDEX NO. 007348/2020 OUN 0:0 NYSCEF BOC. NO. 188 RECEIVED NYSCEF: 02/14/2024 0066183.320146 Kimber Cummings Harris Beach PLLC Imadeh Nosegbe, Dmd v. Zogbam, LLC, et al. Invoice # 895684 Page 3 DATE TIMEKEEPER Hours NARRATIVE TOTAL HOURS AND FEES TOTAL AMOUNT DUE FOR THIS INVOICE... iD: ONONDA PK WV INDEX NO. 007348/2020 OUN 0:0 NYSCEF BOC. NO. 188 RECEIVED NYSCEF: 02/14/2024 HARRIS BEACH z ATTORNEYS AT LAW Kimber Cummings January 31, 2024 6020 Sneller Road Brewerton, NY 13029 Firm Matter Number: 0066183.320146 Invoice #8956841 Firm Attorney: James Muldoon January Invoice for Statement of Services and Disbursements TOTAL AMOUNT DUE FOR THIS INVOICE.... PREVIOUS OUTSTANDING BALANCE FOR THIS MATTER... TOTAL AMOUNT DUE FOR THIS MATTER AS OF CURRENT INVOICE (01/31/24) A late payment penalty .75% per month will be applied to all balances remaining unpaid 30 days after the invoice date and for each 30 day period thereafter. Payment by Credit Card https://www.harrisbeach.com/payment Click on link and you will be directed to the Harr Beach Invoice Payment Page. Please include the Firm Matter Number and Invoice Number which are referenced on this invoice above. Payment by Wire or ACH Bank Name: Citizens Bank, Rochester, NY 14604 Account Name: Harris Beach, PLLC Operating A/C Account 1096 ABA 3103 Swift Code: 1US33 Payment by Check (U.S. Only) Please include this remittance or print your matter and invoice number (8956841) in the check memo. Mail to: HARRIS BEACH PLLC 333 West Washington Street, Suite 200 Syracuse, NY 13202 Reference Information Firm Matter Number: 0066183.320146 Attorney: James Muldoon. For questions please contact: billing @harrisbeach.com Federal Tax Id: BEB 836