On April 12, 2024 a
Exhibit,Appendix
was filed
involving a dispute between
In The Matter Of The Arbitration Attempted To Be Had Between Old Republic Insurance Company,
and
Wei Li,
for Torts - Motor Vehicle
in the District Court of Queens County.
Preview
FILED: QUEENS COUNTY CLERK 04/12/2024 03:27 PM INDEX NO. 707865/2024
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 04/12/2024
Exhibit D
FILED: QUEENS COUNTY CLERK 04/12/2024 03:27 PM INDEX NO. 707865/2024
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 04/12/2024
From: Michael Hemway
To: Kelsey Crowley; KamranA@adr.org
Subject: RE: Wei Li v. Old Republic Insurance Group- SUM - Case 01-23-0001-2771
Date: Wednesday, April 3, 2024 10:54:00 AM
Attachments: image001.png
image002.png
image003.png
image004.png
image005.png
image006.png
Good Morning,
My office represents the Respondent Old Republic Insurance Company in the above referenced matter.
I am writing to request an adjournment of the arbitration scheduled for April 16. The Respondent was not provided with an authorization for Petitioner’s no-
fault records which is needed. Furthermore, Petitioner’s submission includes a dash camera video of the incident which was never provided until today. The
Respondent needs time to review the video and determine its impact on the arbitration and the damages alleged.
Similarly, should that not be sufficient to adjourn the upcoming arbitration, the Respondent intends to subpoena Petitioner’s treating physician, Dr. Merola,
who performed the procedure on Petitioner’s spine. Respondent is requesting the form to subpoena Dr. Merola for his testimony. In addition, Dr. Merola is a
named defendant in a recently filed RICO lawsuit where the allegations include fraud. Respondent is also contemplating filing a Petition to Temporarily Stay
Arbitration until the RICO lawsuit has been resolved so the impact of the lawsuit and its results can be fully realized.
The Respondent is available for a telephone conference should the arbitrator deem it necessary.
Michael J. Hemway, Esq.
Gartner + Bloom attorneys at law
801 Second Avenue, 11th Floor
New York, New York 10017
Phone No.: 212-759-5800 ext. 257
Fax No.: 212-759-5842
mhemway@gartnerbloom.com
CONFIDENTIALITY NOTICE: The information contained in this email, including any attachment(s), is confidential information that may be privileged and
exempt from disclosure under applicable law, and is intended only for the exclusive use by the person(s) mentioned above as recipient(s). If you are not the
intended recipient, you are hereby notified that any disclosure, copying, distribution, or use of the information contained herein is strictly prohibited and may
be unlawful. If you received this transmission in error, please immediately contact the sender and destroy the material in its entirety, whether in electronic or
hard copy format.
From: Kelsey Crowley
Sent: Wednesday, April 3, 2024 9:48 AM
To: KamranA@adr.org; Michael Hemway
Subject: RE: Wei Li v. Old Republic Insurance Group- SUM - Case 01-23-0001-2771
Claimant is ready to proceed and will be sending the submission over momentarily.
Regards,
Kelsey M. Crowley, Esq.
Caesar, Napoli & Spivak PLLC
The Woolworth Building
233 Broadway, Suite 2348
New York, NY 10279
Direct Dial: 646.405.9625
P: 212.226.2100 | F: 212.226.3224
www.caesarnapoli.com
CONFIDENTIALITY NOTICE: This message is intended for the sole use of the intended recipient(s) and may contain confidential and privileged attorney-client information which is protected by
law. Any unauthorized review, use, disclosure, printing, copying or distribution of this communication or its attachments is strictly prohibited. If you are not the intended recipient, please contact the
sender by reply e-mail and destroy all copies of the original message together with any attachments thereto.
From: KamranA@adr.org
Sent: Wednesday, April 3, 2024 9:40 AM
To: Kelsey Crowley ; MHemway@gartnerbloom.com
Subject: Wei Li v. Old Republic Insurance Group- SUM - Case 01-23-0001-2771
You don't often get email from kamrana@adr.org. Learn why this is important
Hello,
FILED: QUEENS COUNTY CLERK 04/12/2024 03:27 PM INDEX NO. 707865/2024
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 04/12/2024
Please review the attached correspondence regarding the above-referenced case.
Feel free to contact me with any questions, comments or concerns you have related to this matter.
Thank you.
Ansa Kamran
Case Administrator
American Arbitration Association
32 Old Slip, 33rd Floor, New York, NY 10005
www.adr.org
T: 917 438 1548
F: 917 438 1769
The information in this transmittal (including attachments, if any) is privileged and/or confidential and is intended only for the recipient(s) listed above. Any review, use, disclosure, distribution or copying of this transmittal is prohibited
except by or on behalf of the intended recipient. If you have received this transmittal in error, please notify me immediately by reply email and destroy all copies of the transmittal. Thank you.
Document Filed Date
April 12, 2024
Case Filing Date
April 12, 2024
Category
Torts - Motor Vehicle
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Preview
FILED: QUEENS COUNTY CLERK 04/12/2024 03:27 PM INDEX NO. 707865/2024 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 04/12/2024 Exhibit D FILED: QUEENS COUNTY CLERK 04/12/2024 03:27 PM INDEX NO. 707865/2024 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 04/12/2024 From: Michael Hemway To: Kelsey Crowley; KamranA@adr.org Subject: RE: Wei Li v. Old Republic Insurance Group- SUM - Case 01-23-0001-2771 Date: Wednesday, April 3, 2024 10:54:00 AM Attachments: image001.png image002.png image003.png image004.png image005.png image006.png Good Morning, My office represents the Respondent Old Republic Insurance Company in the above referenced matter. I am writing to request an adjournment of the arbitration scheduled for April 16. The Respondent was not provided with an authorization for Petitioner’s no- fault records which is needed. Furthermore, Petitioner’s submission includes a dash camera video of the incident which was never provided until today. The Respondent needs time to review the video and determine its impact on the arbitration and the damages alleged. Similarly, should that not be sufficient to adjourn the upcoming arbitration, the Respondent intends to subpoena Petitioner’s treating physician, Dr. Merola, who performed the procedure on Petitioner’s spine. Respondent is requesting the form to subpoena Dr. Merola for his testimony. In addition, Dr. Merola is a named defendant in a recently filed RICO lawsuit where the allegations include fraud. Respondent is also contemplating filing a Petition to Temporarily Stay Arbitration until the RICO lawsuit has been resolved so the impact of the lawsuit and its results can be fully realized. The Respondent is available for a telephone conference should the arbitrator deem it necessary. Michael J. Hemway, Esq. Gartner + Bloom attorneys at law 801 Second Avenue, 11th Floor New York, New York 10017 Phone No.: 212-759-5800 ext. 257 Fax No.: 212-759-5842 mhemway@gartnerbloom.com CONFIDENTIALITY NOTICE: The information contained in this email, including any attachment(s), is confidential information that may be privileged and exempt from disclosure under applicable law, and is intended only for the exclusive use by the person(s) mentioned above as recipient(s). If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, or use of the information contained herein is strictly prohibited and may be unlawful. If you received this transmission in error, please immediately contact the sender and destroy the material in its entirety, whether in electronic or hard copy format. From: Kelsey Crowley Sent: Wednesday, April 3, 2024 9:48 AM To: KamranA@adr.org; Michael Hemway Subject: RE: Wei Li v. Old Republic Insurance Group- SUM - Case 01-23-0001-2771 Claimant is ready to proceed and will be sending the submission over momentarily. Regards, Kelsey M. Crowley, Esq. Caesar, Napoli & Spivak PLLC The Woolworth Building 233 Broadway, Suite 2348 New York, NY 10279 Direct Dial: 646.405.9625 P: 212.226.2100 | F: 212.226.3224 www.caesarnapoli.com CONFIDENTIALITY NOTICE: This message is intended for the sole use of the intended recipient(s) and may contain confidential and privileged attorney-client information which is protected by law. Any unauthorized review, use, disclosure, printing, copying or distribution of this communication or its attachments is strictly prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message together with any attachments thereto. From: KamranA@adr.org Sent: Wednesday, April 3, 2024 9:40 AM To: Kelsey Crowley ; MHemway@gartnerbloom.com Subject: Wei Li v. Old Republic Insurance Group- SUM - Case 01-23-0001-2771 You don't often get email from kamrana@adr.org. Learn why this is important Hello, FILED: QUEENS COUNTY CLERK 04/12/2024 03:27 PM INDEX NO. 707865/2024 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 04/12/2024 Please review the attached correspondence regarding the above-referenced case. Feel free to contact me with any questions, comments or concerns you have related to this matter. Thank you. Ansa Kamran Case Administrator American Arbitration Association 32 Old Slip, 33rd Floor, New York, NY 10005 www.adr.org T: 917 438 1548 F: 917 438 1769 The information in this transmittal (including attachments, if any) is privileged and/or confidential and is intended only for the recipient(s) listed above. Any review, use, disclosure, distribution or copying of this transmittal is prohibited except by or on behalf of the intended recipient. If you have received this transmittal in error, please notify me immediately by reply email and destroy all copies of the transmittal. Thank you.