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ALSTONSBIRDiu»
90 Park Avenue
New York, NY 10016
212-210-9400
Fax; 212-922-3884
www.alston.com
Michael E. Johnson Direct Dial: 212-210-9584 Email: michael.johnson@alston.com
February 2, 2016
VIA EMAIL (timothymcenaney@gmail.com)
Timothy McEnaney, Esq.
14 Vanderventer Avenue
Ste 250
Port Washington, NY 11050
Re: Perez v. Tedesco
Index No. 063193/2013
Dear Tim:
I write in response to your letter of February 1, 2016 concerning the parties’
discovery demands.
We were both surprised and very concerned to learn that Plaintiff has apparently
failed to produce “several hundred thousand emails” containing potentially relevant
information, as referenced on the first page of your letter. Obviously these materials
should have been reviewed and produced months ago. In light of your disclosure, we
cannot understand your statements that Mr. Perez has produced “everything” (emphasis
in original) and has “nothing more to give” with respect to my clients’ document
demands. Mr. Perez should …
