Preview
FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021
NYSCEF DOC. NO. 199 RECEIVED NYSCEF: 08/10/2023
Exhibit X
FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021
NYSCEF DOC. NO. 199 RECEIVED NYSCEF: 08/10/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF WESTCHESTER: CIVIL TERM
X
NEIL B. RICE,
: Index No.:
Plaintiff, : 61665-2021
-against-
LEE R. EINSIDLER, AS ADMINISTRATOR OF THE
ESTATE OF AARON M. EINSIDLER,
Defendant. :
X
WESTCHESTER COUNTY COURTHOUSE
111 Dr. Martin Luther King, Jr. Blvd.
White Plains, New York 10601
July 6, 2023
B E F O R E:
HONORABLE HAL B. GREENWALD
Justice of the Supreme Court
APPEARANCE S:
FOR THE PLAINTIFF:
YANKWITT, LLP
BY: JONATHAN OHRING, ESQ.
RUSSELL YANKWITT, ESQ.
FOR THE DEFENDANT:
ROSMAN LEGAL
BY: STEVEN BRUNNLEHRMAN, of Counsel
ANN M. DEL VECCHIO-KLINGEBIEL, RPR, CRR
SENIOR COURT REPORTER
FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021
NYSCEF DOC. NO. 199 RECEIVED NYSCEF: 208/10/2023
PROCEEDINGS
1 SENIOR COURT CLERK BOBBI JO GREENE: Neil Rice
2 versus Lee Einsidler; index 61665 of 2021.
3 Please state your name for the appearance.
4 ATTORNEY S. BRUNNLEHRMAN: Steven Brunnlehrman --
5 of counsel to Rosman Legal -- for the plaintiff.
6 ATTORNEY J. OHRING: Jonathan Ohring -- Yankwitt,
7 LLP -- for the defendant, Lee Einsidler.
8 ATTORNEY R. YANKWITT: Russell Yankwitt --
9 Yankwitt, LLP -- for the defendant.
10 DEFENDANT LEE EINSIDLER: Lee Einsidler.
11 ATTORNEY J. OHRING: Our client is present.
12 THE COURT: Have a seat. We're here for an order
13 to show cause by plaintiff's counsel to be relieved. Any
14 opposition to the order to show cause?
15 ATTORNEY J. OHRING: Yes, Your Honor.
16 THE COURT: Do you want a briefing schedule?
17 ATTORNEY J. OHRING: No. I mean, I don't think
18 we need a briefing schedule. I mean, we can explain our
19 position right now.
20 THE COURT: Counsel.
21 ATTORNEY S. BRUNNLEHRMAN: Your Honor, it says
22 here that if a briefing schedule is necessary, it will be
23 set on the return date. Since they're opposing it, I
24 understand this to say let's put it in the briefing
25 schedule.
FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021
NYSCEF DOC. NO. 199 RECEIVED NYSCEF: 308/10/2023
PROCEEDINGS
1 THE COURT: Well, maybe I don't need a briefing
2 schedule because they'll going to tell me, in the next ten
3 minutes, what the issue is --
4 ATTORNEY J. OHRING: Yes.
5 THE COURT: -- and I'll decide what it is I need
6 to decide.
7 Are you opposing the application to be relieved?
8 ATTORNEY J. OHRING: So, we are not opposing
9 plaintiff's counsel withdrawing. I mean, frankly, we don't
10 care.
11 THE COURT: Well, that's fine, so I'll grant the
12 application.
13 ATTORNEY J. OHRING: Well, but that wasn't the
14 sole relief sought in the motion. They also were seeking a
15 stay of 30 days -- a stay of the case for 30 days.
16 THE COURT: Which is fairly typical when a firm
17 is relieved.
18 ATTORNEY J. OHRING: But, Your Honor, this is not
19 a typical case, and I'd like to explain.
20 THE COURT: Most of my cases are not typical
21 cases. I don't have typical cases. They're all
22 individual. I understand the nature of this case. It's a
23 little bit -- a lot different than most, to say the least.
24 ATTORNEY J. OHRING: Agreed, Your Honor, but I
25 also think this is not a typical motion to withdraw. This
FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021
NYSCEF DOC. NO. 199 RECEIVED NYSCEF: 408/10/2023
PROCEEDINGS
1 is a motion to withdraw in which plaintiff's counsel has
2 essentially undermined the very notion that the alleged
3 assault occurred.
4 They said, and I quote, that the text messages
5 sent from their client to our client, just a month ago,
6 seemingly prejudiced the plaintiff's entire cause of action
7 against defendant. They also said the contents of the
8 alleged text messages -- this is a quote -- are in direct
9 opposition to plaintiff's theory of the case.
10 They're essentially telling the Court that their
11 client, the plaintiff, has no case, which confirms
12 everything we've known since the day it was filed; that
13 this was an attempt at extortion of my client who is the
14 CEO of Casamigos. This is a person of means.
15 The person -- after they filed --
16 THE COURT: I'm just going to stop you for a
17 second. I think it might be -- the language is poor --
18 fairer or more fair to your client if you actually put in
19 what you're going to tell me in writing?
20 I don't know what other relief you're seeking
21 besides -- I mean, relief is typically being sought and is
22 being sought here by plaintiff's counsel to be relieved.
23 Some of the items that they mentioned in their
24 affidavit -- affirmation of support are questionable or
25 cause me to have some issues. I've read through this case.
FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021
NYSCEF DOC. NO. 199 RECEIVED NYSCEF: 508/10/2023
PROCEEDINGS
1 I mean, it's not something that I haven't participated in
2 in terms of reviewing it and trying to understand exactly
3 the nature of this case. Maybe I can't even understand the
4 nature of it, frankly.
5 What other relief, other than allowing
6 plaintiff's counsel to be relieved, will you be seeking?
7 ATTORNEY J. OHRING: So, here's what I expected
8 to occur today. So, the Court's order said that parties
9 and counsel would appear. So, what I expected and what I
10 hoped is that after -- our client has incurred tremendous
11 legal fees and has exhausted the trust fund -- his son's
12 estate that was set up for his daughter -- for Aaron's
13 daughter, that money has been squander on this case.
14 What I had hoped is that after everything that's
15 happened in this case is that today, Mr. Rice, the
16 plaintiff, would be here, as the Court had required, and
17 tell the Court why this case should continue, in light of
18 the admissions, and the affirmation and the evidence that's
19 been put before this Court by plaintiff's counsel.
20 That was the expectation was to essentially show
21 cause why this case shouldn't continue, and if not, why he
22 should not and counsel should not be sanctioned for
23 bringing a frivolous case.
24 THE COURT: Okay. I understand your points. I
25 think you might be better served if you brought it to my
FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021
NYSCEF DOC. NO. 199 RECEIVED NYSCEF: 608/10/2023
PROCEEDINGS
1 attention in a cross-motion. I wouldn't be able -- I don't
2 think I can grant what you're seeking. I don't know
3 exactly what it is that you're seeking, but I would relieve
4 counsel, for argument's sake. I would grant the
5 application to be relieved.
6 What you're seeking me to do, I think is you want
7 me to remedy the idea that this might have been a frivolous
8 action?
9 ATTORNEY J. OHRING: Yes, Your Honor.
10 ATTORNEY R. YANKWITT: Yes.
11 THE COURT: At this stage -- this argument today
12 is not really the proper place for me to do that.
13 You don't really object to him being relieved,
14 what you object to is the case continuing?
15 ATTORNEY J. OHRING: Yes, that's right,
16 Your Honor.
17 THE COURT: So that, in sum and substance, seems
18 to be what would be the subject of a motion or a
19 cross-motion to dismiss, which is what you're basically
20 telling me.
21 ATTORNEY J. OHRING: Yes, and perhaps a
22 cross-motion for sanctions as well as against plaintiff and
23 counsel, yes.
24 THE COURT: I think that's something that you're
25 free to do. I don't want to impede on your freedom to do
FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021
NYSCEF DOC. NO. 199 RECEIVED NYSCEF: 708/10/2023
PROCEEDINGS
1 that by just hearing you tell it to me. You appear to be
2 prepared to do so, but it seems that it would make more
3 sense if you -- not that I need another motion, but I think
4 it might make more sense if you put it in writing for me to
5 decide whether there's any validity to what you're seeking.
6 Maybe I dismiss the action; maybe I don't. Maybe
7 I fine for sanctions; maybe I don't. But without it being
8 in front of me in paper, I think I can't do it justice. It
9 sounds material, but literally, I can't do it justice by
10 just hearing your argument. It doesn't seem to be fair to
11 both sides.
12 ATTORNEY J. OHRING: May I have a minute,
13 Your Honor, just to consult with our client?
14 THE COURT: Yes, please. I can grant an
15 application for a briefing schedule for you to do your
16 opposition or your cross-motion and then counsel would have
17 an opportunity to reply.
18 ATTORNEY J. OHRING: Yes.
19 THE COURT: Because if you're seeking sanctions,
20 I would want counsel for plaintiff to have an opportunity
21 to defend that.
22 ATTORNEY J. OHRING: Understood, Your Honor, yes.
23 THE COURT: So tell me how much time you think
24 you might need to do a full opposition and a cross-motion?
25 Thirty days? You tell me what you need.
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NYSCEF DOC. NO. 199 RECEIVED NYSCEF: 808/10/2023
PROCEEDINGS
1 ATTORNEY J. OHRING: May I look at my calendar,
2 Your Honor?
3 THE COURT: Please.
4 ATTORNEY J. OHRING: Thank you, Your Honor.
5 Your Honor, just so I understand, you would not
6 rule on the motion to withdraw, correct, until this
7 cross-motion would be briefed?
8 THE COURT: Correct.
9 ATTORNEY J. OHRING: Thank you. Your Honor, may
th
10 we just have over 30 days, until August 10 , to file the
11 opposition and cross-motion?
12 THE COURT: And, Counsel, how much time do you
13 need to file a reply? But also, I guess your reply would
14 also be opposition to the cross-motion.
15 ATTORNEY S. BRUNNLEHRMAN: Right.
16 THE COURT: That's where it gets kind of sticky
17 with calculating dates and times.
18 ATTORNEY S. BRUNNLEHRMAN: Right. So, I'm taking
19 my son four days in August to Ohio State University; so, I
20 won't have time to do it then. September -- some sometime
21 in September? Let me get my phone on. It was making noise
22 before so I turned it off.
23 THE COURT: You want 30 days to do a reply and
24 opposition? That brings us to 9/10 -- September 10th.
25 ATTORNEY S. BRUNNLEHRMAN: Let's see.
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NYSCEF DOC. NO. 199 RECEIVED NYSCEF: 908/10/2023
PROCEEDINGS
1 THE COURT: Opposition to the cross-motion.
2 ATTORNEY S. BRUNNLEHRMAN: Yes.
3 THE COURT: So that's opposition, and Counsel for
4 the Defendant, you have an opportunity to do your reply for
5 the cross-motion. Do you want two weeks after that? A
6 week after that? You tell me.
7 ATTORNEY J. OHRING: Right. I'd say a -- let me
8 just look at my calendar. May we have until October 6th
9 for reply?
10 THE COURT: That's the projected date for these
11 matters to be fully submitted, which would be the order to
12 show cause to be relieved and a cross-motion and opposition
13 to that motion. The cross-motion would be seeking a
14 dismissal and possibly sanctions for commencing a frivolous
15 lawsuit.
16 ATTORNEY J. OHRING: Yes, Your Honor.
17 THE COURT: We all understand the issues.
18 ATTORNEY S. BRUNNLEHRMAN: Yes, Your Honor.
19 THE COURT: I'd rather you have sufficient time
20 to do this properly rather than to argue it in front of me
21 today in ten minutes. It doesn't seem to be the right
22 thing to do.
23 ATTORNEY J. OHRING: Understood, Your Honor.
24 ATTORNEY S. BRUNNLEHRMAN: Thank you, Your Honor.
25 SENIOR COURT CLERK BOBBI JO GREENE: So, we've
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PROCEEDINGS
1 have 8/10 for the cross motion? 9/18 for response and the
2 reply by October 6th? Is that what I've got?
3 THE COURT: Opposition and cross-motion to
4 dismiss, 8/10. So, 10/6 is the forecasted date for being
5 fully submitted.
6 Anything else, Counsel?
7 ATTORNEY J. OHRING: So, yes. So, while this
8 briefing is going on, I presume that the current discovery
9 schedule is going to need to be adjourned?
10 THE COURT: Yes, because if I were to grant being
11 relieved, I would stay this for at least 30 days and
12 probably not put it on for 45 or 60 days out from today.
13 ATTORNEY J. OHRING: Yes, Judge.
14 THE COURT: Which brings us into what? Middle of
15 September? Would it affect the matter -- well, I don't
16 know if I can. If my court attorney is going to allow me
17 to do it, to stay the matter until October 6th.
18 ATTORNEY J. OHRING: I think that would be our
19 preference because I think it would make sense because
20 otherwise, we're faced with, for example, a deposition of
21 the plaintiff and there's a pending motion to withdraw as
22 counsel, so --
23 THE COURT: So in effect, the matter will be
24 stayed until October 6th, and I want give you a date to
25 come back. Maybe the week following that or later in the
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PROCEEDINGS
1 week?
2 SENIOR COURT CLERK BOBBI JO GREENE: A date
3 following October 6th?
4 THE COURT: October 6th is right before the
5 Columbus Day weekend and I might be away. So, maybe you
6 can put it on for like the 18th.
7 SENIOR COURT CLERK BOBBI JO GREENE: You want it
8 on a Monday or can you put it on the Tuesday?
9 THE COURT: On the Tuesday or Wednesday.
10 SENIOR COURT CLERK BOBBI JO GREENE: Okay.
11 Morning or afternoon, Judge? What's your preference?
12 THE COURT: Afternoon at two o'clock.
13 SENIOR COURT CLERK BOBBI JO GREENE: Okay. We
14 can either do the 17th or the 18th?
15 THE COURT: We can do the 17th at two o'clock.
16 SENIOR COURT CLERK BOBBI JO GREENE: The 17th at
17 two o'clock.
18 THE COURT: Does that work, Counsel?
19 ATTORNEY J. OHRING: Yes, Your Honor.
20 ATTORNEY S. BRUNNLEHRMAN: I believe so.
21 SENIOR COURT CLERK BOBBI JO GREENE: Is it just a
22 status conference at that point?
23 THE COURT: Well, it might be a decision, but
24 that's what I'd like to do.
25 ATTORNEY J. OHRING: Should we be prepared for
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PROCEEDINGS
1 oral argument on the motions at that time?
2 THE COURT: Okay. I'm sure by that time you will
3 have told me everything that you want to tell me.
4 ATTORNEY J. OHRING: And would you like the
5 parties to attend?
6 THE COURT: It's not necessary from my
7 perspective. If they want to attend, they can. I'm not
8 going to require it.
9 ATTORNEY S. BRUNNLEHRMAN: Thank you, Your Honor.
10 THE COURT: They're always welcome, but they
11 don't have to be here. Okay. I'm not going to say
12 anything else. I'll get myself in trouble.
13 ATTORNEY S. BRUNNLEHRMAN: Thank you, Your Honor.
14 ATTORNEY J. OHRING: Thank you very much,
15 Your Honor.
16 THE COURT: Thank you.
17 * * * * *
18 This is hereby certified to be a true and accurate
19 record of the above proceedings.
20
21
22
23
24
25 ANN M. DEL VECCHIO-KLINGEBIEL. RPR, CRR
Senior Court Reporter
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Aaron's [1] 5/12 because [5] 3/2 correct [2] 8/68/8 5/9
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above [1] 12/19 10/19 COUNTY [2] 1/11/8 3/19
OHRING: [29]
accurate [1] 12/18 been [3] 5/135/19 court [9] 1/11/12 extortion [1] 4/13
ATTORNEY R.
action [3] 4/66/8 6/7 1/234/105/165/17
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CLERK BOBBI JO
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9 away [1] 11/5 consult [1] 7/13 exactly [2] 5/26/3 Honor [20]
contents [1] 4/7 example [1] 10/20 HONORABLE [1] 1/12
9/10 [1] 8/24 B
continue [2] 5/17 exhausted [1] 5/11 hoped [2] 5/105/14
9/18 for [1] 10/1
back [1] 10/25 5/21 expectation [1] how [2] 7/238/12
A basically [1] 6/19 continuing [1] 5/20
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ATTORNEY J. OHRING: - I'd
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FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021
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FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021 NYSCEF DOC. NO. 199 RECEIVED NYSCEF: 08/10/2023 Exhibit X FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021 NYSCEF DOC. NO. 199 RECEIVED NYSCEF: 08/10/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF WESTCHESTER: CIVIL TERM X NEIL B. RICE, : Index No.: Plaintiff, : 61665-2021 -against- LEE R. EINSIDLER, AS ADMINISTRATOR OF THE ESTATE OF AARON M. EINSIDLER, Defendant. : X WESTCHESTER COUNTY COURTHOUSE 111 Dr. Martin Luther King, Jr. Blvd. White Plains, New York 10601 July 6, 2023 B E F O R E: HONORABLE HAL B. GREENWALD Justice of the Supreme Court APPEARANCE S: FOR THE PLAINTIFF: YANKWITT, LLP BY: JONATHAN OHRING, ESQ. RUSSELL YANKWITT, ESQ. FOR THE DEFENDANT: ROSMAN LEGAL BY: STEVEN BRUNNLEHRMAN, of Counsel ANN M. DEL VECCHIO-KLINGEBIEL, RPR, CRR SENIOR COURT REPORTER FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021 NYSCEF DOC. NO. 199 RECEIVED NYSCEF: 208/10/2023 PROCEEDINGS 1 SENIOR COURT CLERK BOBBI JO GREENE: Neil Rice 2 versus Lee Einsidler; index 61665 of 2021. 3 Please state your name for the appearance. 4 ATTORNEY S. BRUNNLEHRMAN: Steven Brunnlehrman -- 5 of counsel to Rosman Legal -- for the plaintiff. 6 ATTORNEY J. OHRING: Jonathan Ohring -- Yankwitt, 7 LLP -- for the defendant, Lee Einsidler. 8 ATTORNEY R. YANKWITT: Russell Yankwitt -- 9 Yankwitt, LLP -- for the defendant. 10 DEFENDANT LEE EINSIDLER: Lee Einsidler. 11 ATTORNEY J. OHRING: Our client is present. 12 THE COURT: Have a seat. We're here for an order 13 to show cause by plaintiff's counsel to be relieved. Any 14 opposition to the order to show cause? 15 ATTORNEY J. OHRING: Yes, Your Honor. 16 THE COURT: Do you want a briefing schedule? 17 ATTORNEY J. OHRING: No. I mean, I don't think 18 we need a briefing schedule. I mean, we can explain our 19 position right now. 20 THE COURT: Counsel. 21 ATTORNEY S. BRUNNLEHRMAN: Your Honor, it says 22 here that if a briefing schedule is necessary, it will be 23 set on the return date. Since they're opposing it, I 24 understand this to say let's put it in the briefing 25 schedule. FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021 NYSCEF DOC. NO. 199 RECEIVED NYSCEF: 308/10/2023 PROCEEDINGS 1 THE COURT: Well, maybe I don't need a briefing 2 schedule because they'll going to tell me, in the next ten 3 minutes, what the issue is -- 4 ATTORNEY J. OHRING: Yes. 5 THE COURT: -- and I'll decide what it is I need 6 to decide. 7 Are you opposing the application to be relieved? 8 ATTORNEY J. OHRING: So, we are not opposing 9 plaintiff's counsel withdrawing. I mean, frankly, we don't 10 care. 11 THE COURT: Well, that's fine, so I'll grant the 12 application. 13 ATTORNEY J. OHRING: Well, but that wasn't the 14 sole relief sought in the motion. They also were seeking a 15 stay of 30 days -- a stay of the case for 30 days. 16 THE COURT: Which is fairly typical when a firm 17 is relieved. 18 ATTORNEY J. OHRING: But, Your Honor, this is not 19 a typical case, and I'd like to explain. 20 THE COURT: Most of my cases are not typical 21 cases. I don't have typical cases. They're all 22 individual. I understand the nature of this case. It's a 23 little bit -- a lot different than most, to say the least. 24 ATTORNEY J. OHRING: Agreed, Your Honor, but I 25 also think this is not a typical motion to withdraw. This FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021 NYSCEF DOC. NO. 199 RECEIVED NYSCEF: 408/10/2023 PROCEEDINGS 1 is a motion to withdraw in which plaintiff's counsel has 2 essentially undermined the very notion that the alleged 3 assault occurred. 4 They said, and I quote, that the text messages 5 sent from their client to our client, just a month ago, 6 seemingly prejudiced the plaintiff's entire cause of action 7 against defendant. They also said the contents of the 8 alleged text messages -- this is a quote -- are in direct 9 opposition to plaintiff's theory of the case. 10 They're essentially telling the Court that their 11 client, the plaintiff, has no case, which confirms 12 everything we've known since the day it was filed; that 13 this was an attempt at extortion of my client who is the 14 CEO of Casamigos. This is a person of means. 15 The person -- after they filed -- 16 THE COURT: I'm just going to stop you for a 17 second. I think it might be -- the language is poor -- 18 fairer or more fair to your client if you actually put in 19 what you're going to tell me in writing? 20 I don't know what other relief you're seeking 21 besides -- I mean, relief is typically being sought and is 22 being sought here by plaintiff's counsel to be relieved. 23 Some of the items that they mentioned in their 24 affidavit -- affirmation of support are questionable or 25 cause me to have some issues. I've read through this case. FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021 NYSCEF DOC. NO. 199 RECEIVED NYSCEF: 508/10/2023 PROCEEDINGS 1 I mean, it's not something that I haven't participated in 2 in terms of reviewing it and trying to understand exactly 3 the nature of this case. Maybe I can't even understand the 4 nature of it, frankly. 5 What other relief, other than allowing 6 plaintiff's counsel to be relieved, will you be seeking? 7 ATTORNEY J. OHRING: So, here's what I expected 8 to occur today. So, the Court's order said that parties 9 and counsel would appear. So, what I expected and what I 10 hoped is that after -- our client has incurred tremendous 11 legal fees and has exhausted the trust fund -- his son's 12 estate that was set up for his daughter -- for Aaron's 13 daughter, that money has been squander on this case. 14 What I had hoped is that after everything that's 15 happened in this case is that today, Mr. Rice, the 16 plaintiff, would be here, as the Court had required, and 17 tell the Court why this case should continue, in light of 18 the admissions, and the affirmation and the evidence that's 19 been put before this Court by plaintiff's counsel. 20 That was the expectation was to essentially show 21 cause why this case shouldn't continue, and if not, why he 22 should not and counsel should not be sanctioned for 23 bringing a frivolous case. 24 THE COURT: Okay. I understand your points. I 25 think you might be better served if you brought it to my FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021 NYSCEF DOC. NO. 199 RECEIVED NYSCEF: 608/10/2023 PROCEEDINGS 1 attention in a cross-motion. I wouldn't be able -- I don't 2 think I can grant what you're seeking. I don't know 3 exactly what it is that you're seeking, but I would relieve 4 counsel, for argument's sake. I would grant the 5 application to be relieved. 6 What you're seeking me to do, I think is you want 7 me to remedy the idea that this might have been a frivolous 8 action? 9 ATTORNEY J. OHRING: Yes, Your Honor. 10 ATTORNEY R. YANKWITT: Yes. 11 THE COURT: At this stage -- this argument today 12 is not really the proper place for me to do that. 13 You don't really object to him being relieved, 14 what you object to is the case continuing? 15 ATTORNEY J. OHRING: Yes, that's right, 16 Your Honor. 17 THE COURT: So that, in sum and substance, seems 18 to be what would be the subject of a motion or a 19 cross-motion to dismiss, which is what you're basically 20 telling me. 21 ATTORNEY J. OHRING: Yes, and perhaps a 22 cross-motion for sanctions as well as against plaintiff and 23 counsel, yes. 24 THE COURT: I think that's something that you're 25 free to do. I don't want to impede on your freedom to do FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021 NYSCEF DOC. NO. 199 RECEIVED NYSCEF: 708/10/2023 PROCEEDINGS 1 that by just hearing you tell it to me. You appear to be 2 prepared to do so, but it seems that it would make more 3 sense if you -- not that I need another motion, but I think 4 it might make more sense if you put it in writing for me to 5 decide whether there's any validity to what you're seeking. 6 Maybe I dismiss the action; maybe I don't. Maybe 7 I fine for sanctions; maybe I don't. But without it being 8 in front of me in paper, I think I can't do it justice. It 9 sounds material, but literally, I can't do it justice by 10 just hearing your argument. It doesn't seem to be fair to 11 both sides. 12 ATTORNEY J. OHRING: May I have a minute, 13 Your Honor, just to consult with our client? 14 THE COURT: Yes, please. I can grant an 15 application for a briefing schedule for you to do your 16 opposition or your cross-motion and then counsel would have 17 an opportunity to reply. 18 ATTORNEY J. OHRING: Yes. 19 THE COURT: Because if you're seeking sanctions, 20 I would want counsel for plaintiff to have an opportunity 21 to defend that. 22 ATTORNEY J. OHRING: Understood, Your Honor, yes. 23 THE COURT: So tell me how much time you think 24 you might need to do a full opposition and a cross-motion? 25 Thirty days? You tell me what you need. FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021 NYSCEF DOC. NO. 199 RECEIVED NYSCEF: 808/10/2023 PROCEEDINGS 1 ATTORNEY J. OHRING: May I look at my calendar, 2 Your Honor? 3 THE COURT: Please. 4 ATTORNEY J. OHRING: Thank you, Your Honor. 5 Your Honor, just so I understand, you would not 6 rule on the motion to withdraw, correct, until this 7 cross-motion would be briefed? 8 THE COURT: Correct. 9 ATTORNEY J. OHRING: Thank you. Your Honor, may th 10 we just have over 30 days, until August 10 , to file the 11 opposition and cross-motion? 12 THE COURT: And, Counsel, how much time do you 13 need to file a reply? But also, I guess your reply would 14 also be opposition to the cross-motion. 15 ATTORNEY S. BRUNNLEHRMAN: Right. 16 THE COURT: That's where it gets kind of sticky 17 with calculating dates and times. 18 ATTORNEY S. BRUNNLEHRMAN: Right. So, I'm taking 19 my son four days in August to Ohio State University; so, I 20 won't have time to do it then. September -- some sometime 21 in September? Let me get my phone on. It was making noise 22 before so I turned it off. 23 THE COURT: You want 30 days to do a reply and 24 opposition? That brings us to 9/10 -- September 10th. 25 ATTORNEY S. BRUNNLEHRMAN: Let's see. FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021 NYSCEF DOC. NO. 199 RECEIVED NYSCEF: 908/10/2023 PROCEEDINGS 1 THE COURT: Opposition to the cross-motion. 2 ATTORNEY S. BRUNNLEHRMAN: Yes. 3 THE COURT: So that's opposition, and Counsel for 4 the Defendant, you have an opportunity to do your reply for 5 the cross-motion. Do you want two weeks after that? A 6 week after that? You tell me. 7 ATTORNEY J. OHRING: Right. I'd say a -- let me 8 just look at my calendar. May we have until October 6th 9 for reply? 10 THE COURT: That's the projected date for these 11 matters to be fully submitted, which would be the order to 12 show cause to be relieved and a cross-motion and opposition 13 to that motion. The cross-motion would be seeking a 14 dismissal and possibly sanctions for commencing a frivolous 15 lawsuit. 16 ATTORNEY J. OHRING: Yes, Your Honor. 17 THE COURT: We all understand the issues. 18 ATTORNEY S. BRUNNLEHRMAN: Yes, Your Honor. 19 THE COURT: I'd rather you have sufficient time 20 to do this properly rather than to argue it in front of me 21 today in ten minutes. It doesn't seem to be the right 22 thing to do. 23 ATTORNEY J. OHRING: Understood, Your Honor. 24 ATTORNEY S. BRUNNLEHRMAN: Thank you, Your Honor. 25 SENIOR COURT CLERK BOBBI JO GREENE: So, we've FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021 NYSCEF DOC. NO. 199 RECEIVED NYSCEF: 1008/10/2023 PROCEEDINGS 1 have 8/10 for the cross motion? 9/18 for response and the 2 reply by October 6th? Is that what I've got? 3 THE COURT: Opposition and cross-motion to 4 dismiss, 8/10. So, 10/6 is the forecasted date for being 5 fully submitted. 6 Anything else, Counsel? 7 ATTORNEY J. OHRING: So, yes. So, while this 8 briefing is going on, I presume that the current discovery 9 schedule is going to need to be adjourned? 10 THE COURT: Yes, because if I were to grant being 11 relieved, I would stay this for at least 30 days and 12 probably not put it on for 45 or 60 days out from today. 13 ATTORNEY J. OHRING: Yes, Judge. 14 THE COURT: Which brings us into what? Middle of 15 September? Would it affect the matter -- well, I don't 16 know if I can. If my court attorney is going to allow me 17 to do it, to stay the matter until October 6th. 18 ATTORNEY J. OHRING: I think that would be our 19 preference because I think it would make sense because 20 otherwise, we're faced with, for example, a deposition of 21 the plaintiff and there's a pending motion to withdraw as 22 counsel, so -- 23 THE COURT: So in effect, the matter will be 24 stayed until October 6th, and I want give you a date to 25 come back. Maybe the week following that or later in the FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021 NYSCEF DOC. NO. 199 RECEIVED NYSCEF: 1108/10/2023 PROCEEDINGS 1 week? 2 SENIOR COURT CLERK BOBBI JO GREENE: A date 3 following October 6th? 4 THE COURT: October 6th is right before the 5 Columbus Day weekend and I might be away. So, maybe you 6 can put it on for like the 18th. 7 SENIOR COURT CLERK BOBBI JO GREENE: You want it 8 on a Monday or can you put it on the Tuesday? 9 THE COURT: On the Tuesday or Wednesday. 10 SENIOR COURT CLERK BOBBI JO GREENE: Okay. 11 Morning or afternoon, Judge? What's your preference? 12 THE COURT: Afternoon at two o'clock. 13 SENIOR COURT CLERK BOBBI JO GREENE: Okay. We 14 can either do the 17th or the 18th? 15 THE COURT: We can do the 17th at two o'clock. 16 SENIOR COURT CLERK BOBBI JO GREENE: The 17th at 17 two o'clock. 18 THE COURT: Does that work, Counsel? 19 ATTORNEY J. OHRING: Yes, Your Honor. 20 ATTORNEY S. BRUNNLEHRMAN: I believe so. 21 SENIOR COURT CLERK BOBBI JO GREENE: Is it just a 22 status conference at that point? 23 THE COURT: Well, it might be a decision, but 24 that's what I'd like to do. 25 ATTORNEY J. OHRING: Should we be prepared for FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021 NYSCEF DOC. NO. 199 RECEIVED NYSCEF: 1208/10/2023 PROCEEDINGS 1 oral argument on the motions at that time? 2 THE COURT: Okay. I'm sure by that time you will 3 have told me everything that you want to tell me. 4 ATTORNEY J. OHRING: And would you like the 5 parties to attend? 6 THE COURT: It's not necessary from my 7 perspective. If they want to attend, they can. I'm not 8 going to require it. 9 ATTORNEY S. BRUNNLEHRMAN: Thank you, Your Honor. 10 THE COURT: They're always welcome, but they 11 don't have to be here. Okay. I'm not going to say 12 anything else. I'll get myself in trouble. 13 ATTORNEY S. BRUNNLEHRMAN: Thank you, Your Honor. 14 ATTORNEY J. OHRING: Thank you very much, 15 Your Honor. 16 THE COURT: Thank you. 17 * * * * * 18 This is hereby certified to be a true and accurate 19 record of the above proceedings. 20 21 22 23 24 25 ANN M. DEL VECCHIO-KLINGEBIEL. RPR, CRR Senior Court Reporter FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021 NYSCEF DOC. NO. 199 RECEIVED NYSCEF: 08/10/2023 Aaron's [1] 5/12 because [5] 3/2 correct [2] 8/68/8 5/9 able [1] 6/1 7/1910/1010/19 counsel [20] explain [2] 2/18 ATTORNEY J. above [1] 12/19 10/19 COUNTY [2] 1/11/8 3/19 OHRING: [29] accurate [1] 12/18 been [3] 5/135/19 court [9] 1/11/12 extortion [1] 4/13 ATTORNEY R. action [3] 4/66/8 6/7 1/234/105/165/17 YANKWITT: [2] 2/8 F 7/6 before [3] 5/19 5/1910/1612/25 6/10 actually [1] 4/18 8/2211/4 Court's [1] 5/8 faced [1] 10/20 ATTORNEY S. adjourned [1] 10/9 being [6] 4/214/22 COURTHOUSE [1] 1/8 fair [2] 4/187/10 BRUNNLEHRMAN: ADMINISTRATOR [1] 6/137/710/410/10 cross [14] fairer [1] 4/18 [11] 2/42/218/15 1/5 believe [1] 11/20 cross-motion [13] fairly [1] 3/16 8/188/259/29/18 admissions [1] besides [1] 4/21 CRR [2] 1/2312/25 fees [1] 5/11 9/2411/2012/912/13 5/18 better [1] 5/25 current [1] 10/8 file [2] 8/108/13 DEFENDANT LEE affect [1] 10/15 bit [1] 3/23 filed [2] 4/124/15 EINSIDLER: [1] D affidavit [1] 4/24 Blvd [1] 1/8 fine [2] 3/117/7 2/10 affirmation [2] both [1] 7/11 date [5] 2/239/10 firm [1] 3/16 SENIOR COURT 4/245/18 briefed [1] 8/7 10/410/2411/2 following [2] CLERK BOBBI JO after [5] 4/155/10 briefing [7] 2/16 dates [1] 8/17 10/2511/3 GREENE: [8] 1/24 5/149/59/6 2/182/222/243/1 daughter [2] 5/12 forecasted [1] 9/2511/211/711/10 afternoon [2] 7/1510/8 5/13 10/4 11/1311/1611/21 11/1111/12 bringing [1] 5/23 day [2] 4/1211/5 four [1] 8/19 THE COURT: [40] against [3] 1/44/7 brings [2] 8/24 days [8] 3/153/15 frankly [2] 3/95/4 - 6/22 10/14 7/258/108/198/23 free [1] 6/25 ago [1] 4/5 brought [1] 5/25 10/1110/12 freedom [1] 6/25 Agreed [1] 3/24 BRUNNLEHRMAN [2] decide [3] 3/53/6 frivolous [3] 5/23 all [2] 3/219/17 1/192/4 7/5 6/79/14 X [2] 1/2 alleged [2] 4/24/8 but [11] 3/133/18 decision [1] 11/23 front [2] 7/89/20 1/7 allow [1] 10/16 3/246/37/27/37/7 defend [1] 7/21 full [1] 7/24 -against [1] 1/4 allowing [1] 5/5 7/98/1311/2312/10 defendant [6] 1/7 fully [2] 9/1110/5 1 also [5] 3/143/25 1/182/72/94/79/4 fund [1] 5/11 4/78/138/14 C DEL [2] 1/2312/25 10 [2] 8/2410/4 G always [1] 12/10 calculating [1] deposition [1] 10/6 is [1] 10/4 ANN [2] 1/2312/25 8/17 10/20 get [2] 8/2112/12 10601 [1] 1/9 another [1] 7/3 calendar [2] 8/1 different [1] 3/23 gets [1] 8/16 10th [2] 8/108/24 any [2] 2/137/5 9/8 direct [1] 4/8 give [1] 10/24 111 [1] 1/8 anything [2] 10/6 can [9] 2/186/2 discovery [1] 10/8 going [8] 3/24/16 17th [3] 11/14 12/12 7/1410/1611/611/8 dismiss [3] 6/19 4/1910/810/910/16 11/1511/16 appear [2] 5/97/1 11/1411/1512/7 7/610/4 12/812/11 18th [2] 11/611/14 appearance [1] 2/3 can't [3] 5/37/8 dismissal [1] 9/14 got [1] 10/2 2 application [4] 7/9 do [21] grant [5] 3/116/2 3/73/126/57/15 care [1] 3/10 Does [1] 11/18 6/47/1410/10 2021 [2] 1/32/2 are [5] 3/73/83/20 Casamigos [1] 4/14 doesn't [2] 7/10 GREENWALD [1] 1/12 2023 [1] 1/10 4/84/24 case [13] 9/21 guess [1] 8/13 3 argue [1] 9/20 cases [3] 3/203/21 don't [13] argument [3] 6/11 3/21 Dr [1] 1/8 H 30 [5] 3/153/15 7/1012/1 cause [6] 2/132/14 had [2] 5/145/16 8/108/2310/11 E argument's [1] 6/44/64/255/219/12 HAL [1] 1/12 4 as [5] 1/55/166/22 CEO [1] 4/14 effect [1] 10/23 happened [1] 5/15 6/2210/21 certified [1] EINSIDLER [5] 1/5 has [5] 4/14/11 45 [1] 10/12 assault [1] 4/3 12/18 1/62/22/72/10 5/105/115/13 6 at [10] 4/136/11 CIVIL [1] 1/1 either [1] 11/14 have [15] 8/19/810/1111/12 client [8] 2/114/5 else [2] 10/612/12 haven't [1] 5/1 60 [1] 10/12 11/1511/1611/22 4/54/114/134/18 entire [1] 4/6 he [1] 5/21 61665 [1] 2/2 12/1 5/107/13 ESQ [2] 1/161/16 hearing [2] 7/1 61665-2021 [1] 1/3 attempt [1] 4/13 Columbus [1] 11/5 essentially [3] 7/10 6th [6] 9/810/2 attend [2] 12/5 come [1] 10/25 4/24/105/20 here [5] 2/122/22 10/1710/2411/311/4 12/7 commencing [1] estate [2] 1/65/12 4/225/1612/11 8 attention [1] 6/1 9/14 even [1] 5/3 here's [1] 5/7 8/10 [1] 10/4 attorney [1] 10/16 conference [1] everything [3] hereby [1] 12/18 August [2] 8/10 11/22 4/125/1412/3 him [1] 6/13 8/10 for [1] 10/1 8/19 confirms [1] 4/11 evidence [1] 5/18 his [2] 5/115/12 9 away [1] 11/5 consult [1] 7/13 exactly [2] 5/26/3 Honor [20] contents [1] 4/7 example [1] 10/20 HONORABLE [1] 1/12 9/10 [1] 8/24 B continue [2] 5/17 exhausted [1] 5/11 hoped [2] 5/105/14 9/18 for [1] 10/1 back [1] 10/25 5/21 expectation [1] how [2] 7/238/12 A basically [1] 6/19 continuing [1] 5/20 AARON [1] 1/6 be [31] 6/14 expected [2] 5/7 I I'd [4] 3/199/7 ATTORNEY J. OHRING: - I'd Sheet 1 Page 13 FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021 NYSCEF DOC. NO. 199 RECEIVED NYSCEF: 08/10/2023 I literally [1] 7/9 noise [1] 8/21 1/152/54/115/16 2/8 little [1] 3/23 not [15] 6/227/2010/21 I'd... [2] 9/19 S LLP [3] 1/152/72/9 notion [1] 4/2 plaintiff's [8] 11/24 look [2] 8/19/8 now [1] 2/19 2/133/94/14/64/9 said [3] 4/44/75/8 I'll [3] 3/53/11 lot [1] 3/23 4/225/65/19 sake [1] 6/4 12m/12 0 Luther [1] 1/8 please [3] 2/37/14 sanctioned [1] I' [5] 4/168/18 o'clock [3] 11/12 8/3 5/22 12/212/712/11 M 11/1511/17 point [1] 11/22 sanctions [4] 6/22 I've [2] 4/2510/2 make [3] 7/27/4 object [2] 6/13 points [1] 5/24 7/77/199/14 idea [1] 6/7 10/19 6/14 poor [1] 4/17 say [4] 2/243/23 if [11] 2/224/18 making [1] 8/21 occur [1] 5/8 position [1] 2/19 9/712/11 5/215/257/37/47/19 Martin [1] 1/8 occurred [1] 4/3 possibly [1] 9/14 says [1] 2/21 10/1010/1610/16 material [1] 7/9 October [6] 9/8 preference [2] schedule [7] 2/16 12/7 matter [3] 10/15 10/210/1710/2411/310/1911/11 2/182/222/253/2 impede [1] 6/25 10/1710/23 11/4 prejudiced [1] 4/67/1510/9 in [24] matters [1] 9/11 October 6th [5] prepared [2] 7/2 seat [1] 2/12 incurred [1] 5/10 may [4] 7/128/18/99/810/1710/2411/3 1/25 secon [1] 4/17 index [2] 1/32/2 9/8 11/4 present [1] 2/11 see [1] 8/25 individual [1] maybe [8] 3/15/3 off [1] 8/22 presume [1] 10/8 seeking [9] 3/14 3/22 7/67/67/67/710/25 Ohio [1] 8/19 probably [1] 10/12 4/205/66/26/36/6 into [1] 10/14 11/5 OHRING [2] 1/162/6 proceedings [1] 7/57/199/13 is [31] me [19] Okay [5] 5/2411/1012/19 seem [2] 7/109/21 issue [1] 3/3 mean [5] 2/172/18 11/1312/212/11 projected [1] 9/10 seemingly [1] 4/6 issues [2] 4/25 3/94/215/1 on [12] 2/235/13 proper [1] 6/12 seems [2] 6/177/2 9/17 means [1] 4/14 6/258/68/2110/8 properly [1] 9/20 SENIOR [2] 1/23 it [37] mentioned [1] 4/2310/1211/611/811/8 put [7] 2/244/18 12/25 it's [3] 3/225/1 messages [2] 4/4 11/912/1 5/197/410/1211/6 sense [3] 7/37/4 12/6 4/8 opportunity [3] 11/8 10/19 items [1] 4/23 Middle [1] 10/14 7/177/209/4 sense if [1] 7/3 LT might [7] 4/175/25 opposing [3] 2/23 Q sent [1] 4/5 6/77/47/2411/5 3/73/8 questionable [1] September [4] 8/20 JONATHAN [2] 1/16 11/23 opposition [11] 4/24 8/218/2410/15 2/6 minute [1] 7/12 2/144/97/167/24 quote [2] 4/44/8 September 10th [1] Jr [1] 1/8 minutes [2] 3/3 8/118/148/249/19/3 8/24 Judge [2] 10/13 R 9/21 9/1210/3 served [1] 5/25 11/11 Monday [1] 11/8 or [10] 4/184/24 rather [2] 9/19 set [2] 2/235/12 July [1] 1/10 money [1] 5/13 6/187/1610/1210/25 9/20 should [4] 5/17 just [9] 4/54/16 month [1] 4/5 11/811/911/1111/14 read [1] 4/25 5/225/2211/25 7/17/107/138/58/10 more [3] 4/187/2 oral [1] 12/1 really [2] 6/12 shouldn't [1] 5/21 9/811/21 7/4 order [4] 2/122/14 6/13 show [4] 2/132/14 justice [3] 1/12 Morning [1] 11/11 5/89/11 record [1] 12/19 5/209/12 7/87/9 most [2] 3/203/23 other [3] 4/205/5 relief [4] 3/14 sides [1] 7/11 K motion [22] 5/5 4/204/215/5 since [2] 2/234/12 motions [1] 12/1 otherwise [1] relieve [1] 6/3 so [21] kind [1] 8/16 Mr. [1] 5/15 10/20 relieved [9] 2/13 sole [1] 3/14 King [1] 1/8 Mr. Rice [1] 5/15 our [6] 2/112/18 3/73/174/225/66/5 some [3] 4/234/25 KLINGEBIEL [2] much [3] 7/238/12 4/55/107/1310/18 6/139/1210/11 8/20 1/2312/25 12/14 out [1] 10/12 remedy [1] 6/7 something [2] 5/1 know [3] 4/206/2 my [9] 3/204/13 over [1] 8/10 reply [7] 7/178/13 6/24 10/16 5/258/18/198/219/8 8/138/239/49/910/2 sometime [1] 8/20 known [1] 4/12 P 10/1612/6 REPORTER [2] 1/23 son [1] 8/19 L myself [1] 12/12 paper [1] 7/8 12/25 son's [1] 5/11 participated [1] require [1] 12/8 sought [3] 3/14 language [1] 4/17 N 5/1 required [1] 5/16 4/214/22 later [1] 10/25 name [1] 2/3 parties [2] 5/8 response [1] 10/1 sounds [1] 7/9 lawsuit [1] 9/15 nature [3] 3/225/3 12/5 return [1] 2/23 squander [1] 5/13 least [2] 3/23 5/4 pending [1] 10/21 reviewing [1] 5/2 stage [1] 6/11 10/11 necessary [2] 2/22 perhaps [1] 6/21 RICE [3] 1/22/1 state [3] 1/12/3 LEE [4] 1/52/22/7 12/6 person [2] 4/14 5/15 8/19 2/10 need [8] 2/183/1 4/15 right [7] 2/196/15 status [1] 11/22 legal [3] 1/192/5 3/57/37/247/258/13 perspective [1] 8/158/189/79/21 stay [4] 3/153/15 5/11 10/9 12/7 11/4 10/1110/17 let [2] 8/219/7 NEIL [2] 1/21/24 phone [1] 8/21 ROSMAN [2] 1/192/5 stayed [1] 10/24 let's [2] 2/248/25 NEW [2] 1/11/9 place [1] 6/12 RPR [2] 1/2312/25 STEVEN [2] 1/192/4 light [1] 5/17 next [1] 3/2 Plains [1] 1/9 rule [1] 8/6 sticky [1] 8/16 like [4] 3/1911/6 no [3] 1/32/174/11 plaintiff [8] 1/3 RUSSELL [2] 1/16 stop [1] 4/16 11/2412/4 I'd... - stop Sheet 2 Page 14 FILED: WESTCHESTER COUNTY CLERK 08/10/2023 02:11 PM INDEX NO. 61665/2021 NYSCEF DOC. NO. 199 RECEIVED NYSCEF: 08/10/2023 S Tuesday [2] 11/8 why [3] 5/175/21 11/9 5/21 subject [1] 6/18 turned [1] 8/22 will [4] 2/225/6 submitted [2] 9/11 two [4] 9/511/12 10/2312/2 10/5 11/1511/17 withdraw [4] 3/25 substance [1] 6/17 typical [5] 3/16 4/18/610/21 sufficient [1] 9/19 3/193/203/213/25 withdrawing [1] typically [1] 4/213/9 sum [1] 6/17 without [1] 7/7 support [1] 4/24 U won't [1] 8/20 SUPREME [2] 1/1 undermined [1] 4/2 work [1] 11/18 1/12 understand [7] would [18] sure [1] 12/2 2/243/225/25/35/24 wouldn't [1] 6/1 T 8/59/17 writing [2] 4/19 Understood [2] 7/4 taking [1] 8/18 7/229/23 tell [8] 3/24/19 Y University [1] 5/177/17/237/259/6 8/19 YANKWITT [5] 1/15 12/3 until [5] 8/68/10 1/162/62/82/9 telling [2] 4/10 9/810/1710/24 yes [17] 6/20 up [1] 5/12 YORK [2] 1/11/9 ten [2] 3/29/21 us [2] 8/2410/14 you [40] TERM [1] 1/1 you're [9] 4/19 terms [1] 5/2 V 4/206/26/36/66/19 text [2] 4/44/8 validity [1] 7/5 6/247/57/19 than [3] 3/235/5 VECCHIO [2] 1/23 your [30] 9/20 12/25 Thank [7] 8/48/9 VECCHIO-KLINGEBIEL 9/2412/912/1312/14 [2] 1/2312/25 12/16 versus [1] 2/2 that [37] very [2] 4/212/14 that's [9] 3/11 5/145/186/156/24 W 8/169/39/1011/24 want [10] 2/166/6 their [3] 4/54/10 6/257/208/239/5 4/23 10/2411/712/312/7 then [2] 7/168/20 was [6] 4/124/13 theory [1] 4/9 5/125/205/208/21 there's [2] 7/5 wasn't [1] 3/13 10/21 we [10] 2/182/18 these [1] 9/10 3/83/98/109/89/17 they [8] 3/144/4 11/1311/1511/25 4/74/154/2312/7 we're [2] 2/12 12/712/10 10/20 they'll [1] 3/2 we've [2] 4/129/25 they're [4] 2/23 Wednesday [1] 11/9 3/214/1012/10 week [3] 9/610/25 thing [1] 9/22 11/1 think [12] 2/17 weekend [1] 11/5 3/254/175/256/26/6 weeks [1] 9/5 6/247/37/87/23 welcome [1] 12/10 10/1810/19 well [6] 3/13/11 Thirty [1] 7/25 3/136/2210/1511/23 this [23] were [2] 3/1410/10 through [1] 4/25 WESTCHESTER [2] time [6] 7/238/12 1/11/8 8/209/1912/112/2 what [20] times [1] 8/17 What's [1] 11/11 today [5] 5/85/15 when [1] 3/16 6/119/2110/12 where [1] 8/16 told [1] 12/3 whether [1] 7/5 tremendous [1] which [6] 3/164/1 5/10 4/116/199/1110/14 tro le [1] 12/12 ub while [1] 10/7 true [1] 12/18 White [1] 1/9 trust [1] 5/11 who [1] 4/13 trying [1] 5/2 subject - your Sheet 3 Page 15