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. 12 RECEIVED NYSCEF: 09/13/2017
EXHIBIT D
=: INDEX NO. 150258/2017
NYSCEF DOC. NO. 12 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
March 30, 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, Esq.
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 and Hunter Roberts Construction Group,.
(“Defendants”) in the above-referenced matter.
On February 21, 2017, Defendants served Combined Demands and a Demand for Bill of
Particulars as to Affirmative Defenses. To 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 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/]
U
Jos a M. J al
LE VIS BRISBO! ISGAARD & SMITH LLP
JMI
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
4826-2408-3014.1
Document Filed Date
September 13, 2017
Case Filing Date
January 10, 2017
Category
Torts - Other Negligence (Premises - Labor Law 240)
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