On January 05, 2022 a
Letter,Correspondence
was filed
involving a dispute between
R.D. Geronimo, Ltd,
Richard J. Digeronimo,
and
Archstone Group Nyc Llc,
Michael Miller,
Property Analytix, Llc,
Royce Ashton Rowles,
Ryan Lin,
for Commercial Division - Contract
in the District Court of Nassau County.
Preview
R OSMA N L EGA L , P.C.
7-11 S OUTH B ROADWAY /S UITE 209
W HITE P LAINS , N EW Y ORK 10601
P HONE : 914-339-9870
November 3, 2022
By Email and NYSCEF
Hon. Damaris E. Torrent, A.J.S.C.
Supreme Court, Westchester County
111 Dr. Martin Luther King Jr. Blvd.
White Plains, NY 10601
IAS Part 28 – Courtroom 1201
Re: Rice v. Einsidler, Index No. 61665/2021
To the Honorable Justice Torrent:
I will not be lowering myself to respond to every accusation in opposing counsel’s over-the-top
diatribe and attempted assassination of my character. I have simply been reporting what I believe
to be the developing circumstances of our ongoing obligation to commit to discovery.
All that I can say is that I am not the one testifying here. Opposing counsel can, at deposition, ask
our client all the questions they want about his cell phone. The texts and other communications
that I expect both sides to be seeking can alternatively be obtained from their respective carriers
and service providers.
Defendant proclaims “shakedown” to deflect from Defendant’s consistent refusal to produce the
discovery actually seminal to both parties’ positions. The Deceased’s cell phone is the source for
both parties of any and all text messages and emails between the Deceased and our client as well
as any photograph(s) of our client. The autopsy photo will evidence whether the alleged “heart-
shaped” tattoo exists as claimed. Defendant’s PayPal and credit card statements will evidence
whether or not our client did meet with Defendant at the particular Shell station, something that
Defendant denies.
We again respectfully request that the Court rule on the Parties’ respective motions at this time.
Very truly yours,
Steven M. Brunnlehrman
cc: Tayisha DuBose-Lopez, Secretary for Justice Torrent, tdlopez@nycourts.gov
C. Guzman, Senior Court Clerk for Justice Torrent, cguzman@nycourts.gov
Margaret A. Kennedy, Principal Court Attorney for Justice Torrent, makenned@nycourts.gov
Brian G. Shaffer, Principal Law Clerk for Justice Torrent, bshaffer@nycourts.gov
Jonathan Ohring, jonathan@yankwitt.com
Document Filed Date
November 03, 2022
Case Filing Date
January 05, 2022
Category
Commercial Division - Contract
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
R OSMA N L EGA L , P.C. 7-11 S OUTH B ROADWAY /S UITE 209 W HITE P LAINS , N EW Y ORK 10601 P HONE : 914-339-9870 November 3, 2022 By Email and NYSCEF Hon. Damaris E. Torrent, A.J.S.C. Supreme Court, Westchester County 111 Dr. Martin Luther King Jr. Blvd. White Plains, NY 10601 IAS Part 28 – Courtroom 1201 Re: Rice v. Einsidler, Index No. 61665/2021 To the Honorable Justice Torrent: I will not be lowering myself to respond to every accusation in opposing counsel’s over-the-top diatribe and attempted assassination of my character. I have simply been reporting what I believe to be the developing circumstances of our ongoing obligation to commit to discovery. All that I can say is that I am not the one testifying here. Opposing counsel can, at deposition, ask our client all the questions they want about his cell phone. The texts and other communications that I expect both sides to be seeking can alternatively be obtained from their respective carriers and service providers. Defendant proclaims “shakedown” to deflect from Defendant’s consistent refusal to produce the discovery actually seminal to both parties’ positions. The Deceased’s cell phone is the source for both parties of any and all text messages and emails between the Deceased and our client as well as any photograph(s) of our client. The autopsy photo will evidence whether the alleged “heart- shaped” tattoo exists as claimed. Defendant’s PayPal and credit card statements will evidence whether or not our client did meet with Defendant at the particular Shell station, something that Defendant denies. We again respectfully request that the Court rule on the Parties’ respective motions at this time. Very truly yours, Steven M. Brunnlehrman cc: Tayisha DuBose-Lopez, Secretary for Justice Torrent, tdlopez@nycourts.gov C. Guzman, Senior Court Clerk for Justice Torrent, cguzman@nycourts.gov Margaret A. Kennedy, Principal Court Attorney for Justice Torrent, makenned@nycourts.gov Brian G. Shaffer, Principal Law Clerk for Justice Torrent, bshaffer@nycourts.gov Jonathan Ohring, jonathan@yankwitt.com