On August 03, 2015 a
Letter,Correspondence
was filed
involving a dispute between
Country-Wide Insurance Company,
and
Tc Acupuncture, P.C. A A O Corey Crichlow,
for Article 75 proceedings
in the District Court of New York County.
Preview
129 LIVINGSTON STREET
GARY TSIRELMAN P Cc. SECOND & THIRD FLOORS
BROOKLYN, NY 11201
T: (718) 438-1200 « F: (718) 438-8883
ATTORNEYS & COUNSELORS AT LAW igolodkeyer@gtmdjd.com
Gary TSIRELMAN M.D. Stefan BELINFANTI Douglas MACE
Darya KLEIN Tlya MURAFA Stephen GURFINKEI
Selina CHIN, Daniel GRACE, Sebastian MELO
Irena GOLODKEYER Nicholas BOWERS Jennifer RAHEB
David GOTTLIEB. Joseph PADRUCCO Evan J. POLANSKY
09/08/2015
Via NYSCEF
Hon. Judge Joan B. Lobis
60 Centre Street
New York, NY 10007
RE: TC Acupuncture, P.C. (a/a/o Corey Crichlow) vs. Country-Wide Index #: 157967/2015
Ins. Co. File #:104.181
Dear Hon. Judge Lobis:
The Petitioner’s Petition in the matter referenced above appeared on this Court’s calendar on
August 26, 2015. It was submitted without our opposition papers. The failure to submit opposition was
not intentional and due to a set of unfortunate circumstances. I was away at the time the Petition was
returnable and only came back on September 6". More importantly, we only received a copy of the
Petition from the client when I returned, after the submission date. In addition, our long-time calendar
clerk responsible for entering appearances into our computer system resigned on August 14, 2015.
At this time we are requesting that your Honor allow us to submit an Answer/Opposition to the
Petition so that the Court is able to decide the matter on the merits. Thank you for your attention to this
matter.
Sincerely,
Gary Tsirelman, Esq.
CC:
Country-Wide Ins. Co.
Attorneys for Defendant
40 Wall St.
New York, NY 10005
Document Filed Date
September 10, 2015
Case Filing Date
August 03, 2015
Category
Article 75 proceedings
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129 LIVINGSTON STREET GARY TSIRELMAN P Cc. SECOND & THIRD FLOORS BROOKLYN, NY 11201 T: (718) 438-1200 « F: (718) 438-8883 ATTORNEYS & COUNSELORS AT LAW igolodkeyer@gtmdjd.com Gary TSIRELMAN M.D. Stefan BELINFANTI Douglas MACE Darya KLEIN Tlya MURAFA Stephen GURFINKEI Selina CHIN, Daniel GRACE, Sebastian MELO Irena GOLODKEYER Nicholas BOWERS Jennifer RAHEB David GOTTLIEB. Joseph PADRUCCO Evan J. POLANSKY 09/08/2015 Via NYSCEF Hon. Judge Joan B. Lobis 60 Centre Street New York, NY 10007 RE: TC Acupuncture, P.C. (a/a/o Corey Crichlow) vs. Country-Wide Index #: 157967/2015 Ins. Co. File #:104.181 Dear Hon. Judge Lobis: The Petitioner’s Petition in the matter referenced above appeared on this Court’s calendar on August 26, 2015. It was submitted without our opposition papers. The failure to submit opposition was not intentional and due to a set of unfortunate circumstances. I was away at the time the Petition was returnable and only came back on September 6". More importantly, we only received a copy of the Petition from the client when I returned, after the submission date. In addition, our long-time calendar clerk responsible for entering appearances into our computer system resigned on August 14, 2015. At this time we are requesting that your Honor allow us to submit an Answer/Opposition to the Petition so that the Court is able to decide the matter on the merits. Thank you for your attention to this matter. Sincerely, Gary Tsirelman, Esq. CC: Country-Wide Ins. Co. Attorneys for Defendant 40 Wall St. New York, NY 10005