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RUBIN, FIORELLA 8 FRIEDMAN LLP
ATTORNEYS AT LAW
3rd
630 Third Avenue, FlOOr
New York, New York 10017
Tel: (212) 953-2381 / Fax: (212) 953-2462
Direct Dial: (212) 447-4639
E-Mail : screenspan rubinliorella.com
March 19, 2018
Supreme Court, Bronx County
851 Grand Concourse
Bronx, New York 10451
Attention: Honorable Justice Doris M. Gonzalez
RE: FELICIANO, KALIMAR v. ADEE REALTY LLC, et al
Index No.: 20551/2013E
Our File No.: 708.26997
Dear Justice Gonzalez:
We represent defendant, ADEE REALTY, LLC. in connection with the action referenced
above. We are in receipt of a letter dated March 19, 2018, as written by James F. Sullivan, trial
counsel to The Felicetti Law Firm, requesting that the trialof this action, presently scheduled for
April 16, 2018, be adjourned to the week of May 14, 2018. Inasmuch as I would like to
accommodate Mr. Sullivan, the date(s) Mr. Sullivan is/are requesting conflict with my own trial
schedule. On May 18, 2018, I am scheduled to start a trial in the case DeLaRosa v. Nelson
Avenue Holdings, LLC and Michael Black, which is also pending in Bronx County (Index No.:
302047/14); on May 30, 2018, I am scheduled to try Tejada v. Southern Boulevard Partners,
again a Bronx County case (Index No.: 308998/12); and on May 31, 2018, I am scheduled to try
Vargas v. Fortress CD LLC. (Index No.: 306572/14), although I believe the Vargas case is
scheduled for a conference, rather than jury selection.
The instant case, Feliciano, is a very expert intensive case. On the defense side alone, we
expect to call three (3) IME doctors, Berman, Carciante and Erlanger, as well as a biomechanic,
vocational rehab specialist and possibly an economist. In deciding on the April 16, 2018 date, all
of these experts were generally available. I understand that Mr. Sullivan has personal and
professional commitments which conflict with the April 16, 2018 trialdate and certainly would
like to accommodate him in any way I can. However, the date(s) he proposes are just not
workable. Should the Court be inclined to move the trial date, I would be more than happy to
conference the case ahead of April 16, 2018, in order that both myself and Mr. Sullivan may
select a mutually acceptable date that works not only for us, but our retained experts. As we will
soon need to advance monies to secure the appearance of our experts, we would ask that if the
Court wishes to schedule a conference to re-set the trialdate, that itplease do so as soon as
Supreme Court, Bronx County
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possible, as the fees are likely to be nonrefundable should the trialdate be moved.
Thank-you for your kind attention.
Ve ,
St rt . Greenspan
SBG:tis
cc: Law Offices of
James F. Sullivan, P.C.
7th
52 Duane Street, FlOOr
New York, New York 10007
The Felicetti Law Firm
557 Grand Concourse, Suite 159
Bronx, New York 10451
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RUBIN, FIORELLA 8 FRIEDMAN LLP ATTORNEYS AT LAW 3rd 630 Third Avenue, FlOOr New York, New York 10017 Tel: (212) 953-2381 / Fax: (212) 953-2462 Direct Dial: (212) 447-4639 E-Mail : screenspan rubinliorella.com March 19, 2018 Supreme Court, Bronx County 851 Grand Concourse Bronx, New York 10451 Attention: Honorable Justice Doris M. Gonzalez RE: FELICIANO, KALIMAR v. ADEE REALTY LLC, et al Index No.: 20551/2013E Our File No.: 708.26997 Dear Justice Gonzalez: We represent defendant, ADEE REALTY, LLC. in connection with the action referenced above. We are in receipt of a letter dated March 19, 2018, as written by James F. Sullivan, trial counsel to The Felicetti Law Firm, requesting that the trialof this action, presently scheduled for April 16, 2018, be adjourned to the week of May 14, 2018. Inasmuch as I would like to accommodate Mr. Sullivan, the date(s) Mr. Sullivan is/are requesting conflict with my own trial schedule. On May 18, 2018, I am scheduled to start a trial in the case DeLaRosa v. Nelson Avenue Holdings, LLC and Michael Black, which is also pending in Bronx County (Index No.: 302047/14); on May 30, 2018, I am scheduled to try Tejada v. Southern Boulevard Partners, again a Bronx County case (Index No.: 308998/12); and on May 31, 2018, I am scheduled to try Vargas v. Fortress CD LLC. (Index No.: 306572/14), although I believe the Vargas case is scheduled for a conference, rather than jury selection. The instant case, Feliciano, is a very expert intensive case. On the defense side alone, we expect to call three (3) IME doctors, Berman, Carciante and Erlanger, as well as a biomechanic, vocational rehab specialist and possibly an economist. In deciding on the April 16, 2018 date, all of these experts were generally available. I understand that Mr. Sullivan has personal and professional commitments which conflict with the April 16, 2018 trialdate and certainly would like to accommodate him in any way I can. However, the date(s) he proposes are just not workable. Should the Court be inclined to move the trial date, I would be more than happy to conference the case ahead of April 16, 2018, in order that both myself and Mr. Sullivan may select a mutually acceptable date that works not only for us, but our retained experts. As we will soon need to advance monies to secure the appearance of our experts, we would ask that if the Court wishes to schedule a conference to re-set the trialdate, that itplease do so as soon as Supreme Court, Bronx County Page Two possible, as the fees are likely to be nonrefundable should the trialdate be moved. Thank-you for your kind attention. Ve , St rt . Greenspan SBG:tis cc: Law Offices of James F. Sullivan, P.C. 7th 52 Duane Street, FlOOr New York, New York 10007 The Felicetti Law Firm 557 Grand Concourse, Suite 159 Bronx, New York 10451