On February 25, 2022 a
Exhibit,Appendix
was filed
involving a dispute between
Be A Good Neighbor Llc,
and
David Leslie,
Mauro Torres,
Torres Millwork & Construction Llc,
for Commercial - Contract
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 04/11/2024 12:18 PM INDEX NO. 650901/2022
NYSCEF DOC. NO. 101 RECEIVED NYSCEF: 04/11/2024
Zachary Rosenberg
From: michelle@zzllp.com
Sent: Tuesday, April 2, 2024 10:24 AM
To: Zachary Rosenberg
Cc: joem@zzllp.com; Jennifer Kreder
Subject: RE: Deposition
CAUTION: This email originated from outside of Rottenberg Lipman, Rich, P.C. Do not click links or open attachments unless you
recognize the sender and know the content is safe.
We won’t consent to your amended complaint. We can talk tomorrow regarding the proposed status order.
WE HAVE MOVED. Please note our new address below.
Meng Michelle Cheng, Esq.
ZISHOLTZ & ZISHOLTZ, LLP
200 Garden City Plaza, Suite 408,
Garden City, New York 11530
Tel: (516) 741-2200 Fax: (516) 746-1024
STATEMENT OF CONFIDENTIALITY
The information contained in this electronic message and any attachments to this message are intended for the exclusive
use of the addressee(s) and may contain confidential or privileged information. If you are not the intended recipient,
please notify us immediately by e-mail reply to sender and destroy all copies of this message and any attachments
From: Zachary Rosenberg
Sent: Friday, March 29, 2024 3:21 PM
To: Michelle Cheng
Subject: FW: Deposition
Michelle,
We still have not received a response to my email below concerning the amended complaint. Defendants’ responses to
Plaintiff’s second document demands are also overdue. Please let me know when we can expect to receive them.
Thanks,
Zack
From: Zachary Rosenberg
Sent: Thursday, February 8, 2024 4:28 PM
To: michelle@zzllp.com
Cc: Joseph McMahon ; Harry Lipman ; Jennifer Kreder
Subject: RE: Deposition
Michelle,
We believe that Mr. Leslie’s testimony demonstrates his personal liability. We intend to proceed with the attached
amended verified complaint adding causes of action for violation of NYC Administrative Code 28-420.1 and 28-
1
FILED: NEW YORK COUNTY CLERK 04/11/2024 12:18 PM INDEX NO. 650901/2022
NYSCEF DOC. NO. 101 RECEIVED NYSCEF: 04/11/2024
420.7 based upon defendants’ testimony. Please let me know if we may file it on consent or if we should proceed
via a motion to amend.
Thanks,
Zack
From: michelle@zzllp.com
Sent: Wednesday, February 7, 2024 3:17 PM
To: Zachary Rosenberg
Subject: RE: Deposition
CAUTION: This email originated from outside of Rottenberg Lipman, Rich, P.C. Do not click links or open attachments unless you
recognize the sender and know the content is safe.
We will not take Plaintiff’s deposition at this time. Also, would you consider to withdraw the claims against David
Leslie based upon his testimony at his deposition?
WE HAVE MOVED. Please note our new address below.
Meng Michelle Cheng, Esq.
ZISHOLTZ & ZISHOLTZ, LLP
200 Garden City Plaza, Suite 408,
Garden City, New York 11530
Tel: (516) 741-2200 Fax: (516) 746-1024
STATEMENT OF CONFIDENTIALITY
The information contained in this electronic message and any attachments to this message are intended for the exclusive
use of the addressee(s) and may contain confidential or privileged information. If you are not the intended recipient,
please notify us immediately by e-mail reply to sender and destroy all copies of this message and any attachments
From: Zachary Rosenberg
Sent: Wednesday, February 7, 2024 7:28 AM
To: Michelle Cheng
Subject: Deposition
Having not heard from you, I assume you're not taking a deposition today. If you would like to take my
clients to position, we can schedule it for a different day.
Get Outlook for Android
2
Document Filed Date
April 11, 2024
Case Filing Date
February 25, 2022
Category
Commercial - Contract
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Preview
FILED: NEW YORK COUNTY CLERK 04/11/2024 12:18 PM INDEX NO. 650901/2022 NYSCEF DOC. NO. 101 RECEIVED NYSCEF: 04/11/2024 Zachary Rosenberg From: michelle@zzllp.com Sent: Tuesday, April 2, 2024 10:24 AM To: Zachary Rosenberg Cc: joem@zzllp.com; Jennifer Kreder Subject: RE: Deposition CAUTION: This email originated from outside of Rottenberg Lipman, Rich, P.C. Do not click links or open attachments unless you recognize the sender and know the content is safe. We won’t consent to your amended complaint. We can talk tomorrow regarding the proposed status order. WE HAVE MOVED. Please note our new address below. Meng Michelle Cheng, Esq. ZISHOLTZ & ZISHOLTZ, LLP 200 Garden City Plaza, Suite 408, Garden City, New York 11530 Tel: (516) 741-2200 Fax: (516) 746-1024 STATEMENT OF CONFIDENTIALITY The information contained in this electronic message and any attachments to this message are intended for the exclusive use of the addressee(s) and may contain confidential or privileged information. If you are not the intended recipient, please notify us immediately by e-mail reply to sender and destroy all copies of this message and any attachments From: Zachary Rosenberg Sent: Friday, March 29, 2024 3:21 PM To: Michelle Cheng Subject: FW: Deposition Michelle, We still have not received a response to my email below concerning the amended complaint. Defendants’ responses to Plaintiff’s second document demands are also overdue. Please let me know when we can expect to receive them. Thanks, Zack From: Zachary Rosenberg Sent: Thursday, February 8, 2024 4:28 PM To: michelle@zzllp.com Cc: Joseph McMahon ; Harry Lipman ; Jennifer Kreder Subject: RE: Deposition Michelle, We believe that Mr. Leslie’s testimony demonstrates his personal liability. We intend to proceed with the attached amended verified complaint adding causes of action for violation of NYC Administrative Code 28-420.1 and 28- 1 FILED: NEW YORK COUNTY CLERK 04/11/2024 12:18 PM INDEX NO. 650901/2022 NYSCEF DOC. NO. 101 RECEIVED NYSCEF: 04/11/2024 420.7 based upon defendants’ testimony. Please let me know if we may file it on consent or if we should proceed via a motion to amend. Thanks, Zack From: michelle@zzllp.com Sent: Wednesday, February 7, 2024 3:17 PM To: Zachary Rosenberg Subject: RE: Deposition CAUTION: This email originated from outside of Rottenberg Lipman, Rich, P.C. Do not click links or open attachments unless you recognize the sender and know the content is safe. We will not take Plaintiff’s deposition at this time. Also, would you consider to withdraw the claims against David Leslie based upon his testimony at his deposition? WE HAVE MOVED. Please note our new address below. Meng Michelle Cheng, Esq. ZISHOLTZ & ZISHOLTZ, LLP 200 Garden City Plaza, Suite 408, Garden City, New York 11530 Tel: (516) 741-2200 Fax: (516) 746-1024 STATEMENT OF CONFIDENTIALITY The information contained in this electronic message and any attachments to this message are intended for the exclusive use of the addressee(s) and may contain confidential or privileged information. If you are not the intended recipient, please notify us immediately by e-mail reply to sender and destroy all copies of this message and any attachments From: Zachary Rosenberg Sent: Wednesday, February 7, 2024 7:28 AM To: Michelle Cheng Subject: Deposition Having not heard from you, I assume you're not taking a deposition today. If you would like to take my clients to position, we can schedule it for a different day. Get Outlook for Android 2