On January 10, 2017 a
Exhibit,Appendix
was filed
involving a dispute between
Anand Mathura,
Myah Mathura,
and
50 West Development Llc,
Hunter Roberts Construction Group, L.L.C.,
for Torts - Other Negligence (Premises - Labor Law 240)
in the District Court of New York County.
Preview
= YORK OUN Kk 09 Dv INDEX NO. 150258/2017
104
NYSCEF BOC. NO. 13 RECEIVED NYSCEF: 09/13/2017
EXHIBIT E
=: INDEX NO. 150258/2017
NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 09/13/2017
B LEWIS
Joshua M. Jemal
77 Water Street, Suite 2100
New York, New York 10005
BRISBOIS
Joshua.Jemal @lewisbrisbois.com
Direct: 646.783.0954
LEWIS BRISBOIS BISGAARD & SMITH LLP
April 19, 2017 File No. 26188.875
VIA U.S. MAIL
Stefanidia & Mironis, LLP
31-10 37" Avenue, Suite 303
Long Island City, New York 11101
Attn: Peter Mironis, q
Re: Anand Mathura and Myah Mathura _v. 50 West Development, LLC and Hunter
Roberts Construction Group, L.L.C.
Date of Loss: December 10, 2014
Dear Mr. Mironis:
We represent Defendants 50 West Development, LLC and Hunter Roberts Construction
Group, L.L.C. (“Defendants”) in the above-referenced matter.
On February 21, 2017, Defendants served Combined Demands and a Demand for Bill of
Particulars as to Aff irmative Defenses. ‘lo date, we have yet to receive a response. Enclosed please
find a copy of Defendants’ Combined Discovery Demands for your reference.
Please be advised that this letter constitutes our final good faith attempt to resolve
outstanding discovery without the need for judicial intervention. In an effort to move this case with
alacrity, we request that you make every attempt to furnish responses within twenty (20) days from
the date of this correspondence.
Thank you for your anticipated cooperation. If you have any questions please feel free to
contact me at any time.
Very truly yours,
\
of
LEWIS BRI OIS BISGAARD & SMITH LLP
IMJ
Enclosures
ARIZONA CALIFORNIA COLORADO + CONNECTICUT FLORIDA GEORGIA ILLINOIS INDIANA KANSAS + KENTUCKY
LOUISIANA MARYLAND MASSACHUSETTS . MISSOURI . NEVADA NEW JERSEY NEW MEXICO NEW YORK
NORTH CAROLINA OHIO OREGON PENNSYLVANIA RHODE ISLAND TEXAS, . WASHINGTON WEST VIRGINIA
4832-4593-9270.1
Document Filed Date
September 13, 2017
Case Filing Date
January 10, 2017
Category
Torts - Other Negligence (Premises - Labor Law 240)
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Preview
= YORK OUN Kk 09 Dv INDEX NO. 150258/2017 104 NYSCEF BOC. NO. 13 RECEIVED NYSCEF: 09/13/2017 EXHIBIT E =: INDEX NO. 150258/2017 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 09/13/2017 B LEWIS Joshua M. Jemal 77 Water Street, Suite 2100 New York, New York 10005 BRISBOIS Joshua.Jemal @lewisbrisbois.com Direct: 646.783.0954 LEWIS BRISBOIS BISGAARD & SMITH LLP April 19, 2017 File No. 26188.875 VIA U.S. MAIL Stefanidia & Mironis, LLP 31-10 37" Avenue, Suite 303 Long Island City, New York 11101 Attn: Peter Mironis, q Re: Anand Mathura and Myah Mathura _v. 50 West Development, LLC and Hunter Roberts Construction Group, L.L.C. Date of Loss: December 10, 2014 Dear Mr. Mironis: We represent Defendants 50 West Development, LLC and Hunter Roberts Construction Group, L.L.C. (“Defendants”) in the above-referenced matter. On February 21, 2017, Defendants served Combined Demands and a Demand for Bill of Particulars as to Aff irmative Defenses. ‘lo date, we have yet to receive a response. Enclosed please find a copy of Defendants’ Combined Discovery Demands for your reference. Please be advised that this letter constitutes our final good faith attempt to resolve outstanding discovery without the need for judicial intervention. In an effort to move this case with alacrity, we request that you make every attempt to furnish responses within twenty (20) days from the date of this correspondence. Thank you for your anticipated cooperation. If you have any questions please feel free to contact me at any time. Very truly yours, \ of LEWIS BRI OIS BISGAARD & SMITH LLP IMJ Enclosures ARIZONA CALIFORNIA COLORADO + CONNECTICUT FLORIDA GEORGIA ILLINOIS INDIANA KANSAS + KENTUCKY LOUISIANA MARYLAND MASSACHUSETTS . MISSOURI . NEVADA NEW JERSEY NEW MEXICO NEW YORK NORTH CAROLINA OHIO OREGON PENNSYLVANIA RHODE ISLAND TEXAS, . WASHINGTON WEST VIRGINIA 4832-4593-9270.1