Preview
Law Offices of
Laurence Jeffrey Weingard
The Fisk Building
57th -
250 West street suite 401
Telephon e No.:(212)974-5200 New York, NY 10107 Facsimile No.: (212)956-9337
March 29, 2018
Robert S. Ondrovic, Esq. (via efiling) & email: rondrovic@bcohlaw f frm.com
Boggeman, Corde, Ondrovic & Hurley, P.C.
Stacy ..(i
L. .I Jacobs,Esq. (via efiling) & email: 3 jacobs@geico.com
Law Office of Bryan M. Kulak
Re: Buonora v. Laquidara - Supreme Putnam - Index No.: 50059/2016
Court, County
Counselors:
Please be advised that as per the attached, Judge Grossman has directed that we participate in a
conference call with the court March 2018 at 9:00 a.m. The number to call is 208-
tomorrow, 30, (845)
7890.
Please do not hesitate to contact our office should you have any questions.
Very truly yours,
L Office of aurence Jeffrey Weingard
By: rrett, Esq., Of Counsel
Amyl
25BOCA-GWFAX -> unknown Page 1 of 1
3/29/2010 3458 PM
03-29-18;02: 59PM; ; # 1/ 3
I1
/I ) Law Offices of
o Laurence Jeffirey Weingard
The Fisk Building
5']* I/'
250 West Strect-—Suite401 /sty /
Telephone No.:
(212) 9745200 New Wrk, NY 10107 /V ~ '
Pacsimilo
xad
No.:(212)9564337
n,~~~0 .."i/"
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March 29, 2018
tX ( %I + 09 tt
via Fax (845) 431-1933
v Pl"
pl"
Hon, Victor G. Grossman
Supreme Court, Putnam l tv g(j~l X
County
/j /
t
0'
Re: Buonora v. Laguidara - Supreme Putnam - Index No.: 50059/2016
Court, County
~s
Dear Judge Grossman
Please be advised that this office represents Plaintiffsin the above-referenced matter. Pursuant to
Your Honor's March 23, 2018 directive, enclosed herewith for ease of reference, party depositions are
presently scheduled to commence Monday, April 2, 2018.
However, ithas recently come to our attention that Defendants have not furnished any discovery
Plaintiffs'
responses with respect to demands as of yet. As of today, with respect to Plaintiff's demands,
Defendant's response to Plaintiff'sDemand for a Verified Bill of Particulars as toAffirmative Defenses and
Combined Demands for Discovery and Inspection, both date February 16, 2017, remain outstanding.
With respect to having recently learned of Defendant's failure to comply with demands, we note
that Defendant's February 28, 2018 Response to Discovery Demand, served in response to a demand by the
Plaintiffs'
Law Office of Bryan M. Kulak, relied upon and incorrectly indicated that prior responses to
demands were attached thereto, however, upon review, none were attached.
The undersigned exchanged the attached good faith letter today, requesting that duplicate copies of
all discovery responses claimed to have been previously served be immediately emailed to our office, but
no response has been forthcoming. Further, we have confirmed with the Law Office of Bryan M. Kulak
Defendants'
that discovery responses remain outstanding to their office as well.
Based upon the foregoing, it would be improper to proceed with depositions as scheduled,
Accordingly, we request an extension of time in which to proceed with party depositions once Defendants
have or'
complied with presently outstanding demands, or to entertain a conference callto address this matter,
given the imminent deposition date.
Thank you for all courtesies extended in conjunction with this matter. Please do not hesitate to
contact our office should you haye any questions.
Very truly yours,
L Office of Laurence Jeffrey Weingard
'
By;,
By: . tt,Esq., Of Counsel
Robert S. Ondrovic, Esq. (via efiling)
Boggeman, Corde, Ondrovio & Hurley, P.C.
Counsel forDefendants
Stacy L. Jacobs,Esq. (via efiling)
Law Office ofBryan M. Kulak
Counsel forDefendant Linda Buonora on Counterclaitn
Counterclaim
Preview
Law Offices of Laurence Jeffrey Weingard The Fisk Building 57th - 250 West street suite 401 Telephon e No.:(212)974-5200 New York, NY 10107 Facsimile No.: (212)956-9337 March 29, 2018 Robert S. Ondrovic, Esq. (via efiling) & email: rondrovic@bcohlaw f frm.com Boggeman, Corde, Ondrovic & Hurley, P.C. Stacy ..(i L. .I Jacobs,Esq. (via efiling) & email: 3 jacobs@geico.com Law Office of Bryan M. Kulak Re: Buonora v. Laquidara - Supreme Putnam - Index No.: 50059/2016 Court, County Counselors: Please be advised that as per the attached, Judge Grossman has directed that we participate in a conference call with the court March 2018 at 9:00 a.m. The number to call is 208- tomorrow, 30, (845) 7890. Please do not hesitate to contact our office should you have any questions. Very truly yours, L Office of aurence Jeffrey Weingard By: rrett, Esq., Of Counsel Amyl 25BOCA-GWFAX -> unknown Page 1 of 1 3/29/2010 3458 PM 03-29-18;02: 59PM; ; # 1/ 3 I1 /I ) Law Offices of o Laurence Jeffirey Weingard The Fisk Building 5']* I/' 250 West Strect-—Suite401 /sty / Telephone No.: (212) 9745200 New Wrk, NY 10107 /V ~ ' Pacsimilo xad No.:(212)9564337 n,~~~0 .."i/" I! ~ ~"~ ) March 29, 2018 tX ( %I + 09 tt via Fax (845) 431-1933 v Pl" pl" Hon, Victor G. Grossman Supreme Court, Putnam l tv g(j~l X County /j / t 0' Re: Buonora v. Laguidara - Supreme Putnam - Index No.: 50059/2016 Court, County ~s Dear Judge Grossman Please be advised that this office represents Plaintiffsin the above-referenced matter. Pursuant to Your Honor's March 23, 2018 directive, enclosed herewith for ease of reference, party depositions are presently scheduled to commence Monday, April 2, 2018. However, ithas recently come to our attention that Defendants have not furnished any discovery Plaintiffs' responses with respect to demands as of yet. As of today, with respect to Plaintiff's demands, Defendant's response to Plaintiff'sDemand for a Verified Bill of Particulars as toAffirmative Defenses and Combined Demands for Discovery and Inspection, both date February 16, 2017, remain outstanding. With respect to having recently learned of Defendant's failure to comply with demands, we note that Defendant's February 28, 2018 Response to Discovery Demand, served in response to a demand by the Plaintiffs' Law Office of Bryan M. Kulak, relied upon and incorrectly indicated that prior responses to demands were attached thereto, however, upon review, none were attached. The undersigned exchanged the attached good faith letter today, requesting that duplicate copies of all discovery responses claimed to have been previously served be immediately emailed to our office, but no response has been forthcoming. Further, we have confirmed with the Law Office of Bryan M. Kulak Defendants' that discovery responses remain outstanding to their office as well. Based upon the foregoing, it would be improper to proceed with depositions as scheduled, Accordingly, we request an extension of time in which to proceed with party depositions once Defendants have or' complied with presently outstanding demands, or to entertain a conference callto address this matter, given the imminent deposition date. Thank you for all courtesies extended in conjunction with this matter. Please do not hesitate to contact our office should you haye any questions. Very truly yours, L Office of Laurence Jeffrey Weingard ' By;, By: . tt,Esq., Of Counsel Robert S. Ondrovic, Esq. (via efiling) Boggeman, Corde, Ondrovio & Hurley, P.C. Counsel forDefendants Stacy L. Jacobs,Esq. (via efiling) Law Office ofBryan M. Kulak Counsel forDefendant Linda Buonora on Counterclaitn Counterclaim