On July 26, 2019 a
Exhibit,Appendix
was filed
involving a dispute between
Abel Hernandez,
and
Claudio Garcia,
Quest Bam April 2016 Llc,
for Torts - Motor Vehicle
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 05/08/2020 12:13 PM INDEX NO. 157343/2019
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 05/08/2020
B BAMUNDO ZWAL
&SCHERMERHORNu,
LAW O F F 1C E S
111 JOHN STREET, SUrrE 1100, NEW YORK, NY 10038
TEL: 212-608-8840 FAX: 212-608-8039 E-FAX: 917-591-9525
E-MAIL: BZS@BZSLAW.COM Associates
Partners
Steven Bamundo Ben Bartolotta
Michael C. Zwal *Michael O'Beirne
James R. Schermerhorn **Edward W. Chen
James M. Caffrey Pavlo Paviatos
Bartholomew T. Russo BrianS. Lent
Alex Kheyman
Kat Januszkiewicz
*Admittedin NJ
**Admittedin NJ & DC
October 2, 2019
Ami Morgenstern, Esq.
Attorney at Law, PLLC
2nd
40-17 Broadway, Fl.
P.O. Box 3223
Long Island City, New York 11103-0223
Re: Abel Hernandez v. Claudio Garcia and Quest Bam April 2016, LLC
Our file no.: GLI 7203
Dear Counselors:
As you are aware, we are the attorneys who represeñt the Defendants, Claudio Garcia and
Quest Bam April 2016, LLC, relative to the above-mentioned matter.
On August 20, 2019, this office served upon you our Verified Answer, along with various
discovery demands, including, but not limited to our Demand for a Verified Bill of Particulars.
To date, we have not received responses to our demands. Therefore, kindly consider this
faith"
letter our "good attempt to obtain plaintiff's compliance. Please serve responses to our
demands within the next fourteen (14) days. or we will have no alternative, but to request
the Court's intervention.
Very truly yours,
BAMUND ZWAL & SCHERMERHORN, LLP
r . t,Esq.
BSL/ce
ADDITIONAL OFFICE:
160 SOUTH CENTRAL AVENUE ELMSFORD, NY 10523
Document Filed Date
May 08, 2020
Case Filing Date
July 26, 2019
Category
Torts - Motor Vehicle
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FILED: NEW YORK COUNTY CLERK 05/08/2020 12:13 PM INDEX NO. 157343/2019 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 05/08/2020 B BAMUNDO ZWAL &SCHERMERHORNu, LAW O F F 1C E S 111 JOHN STREET, SUrrE 1100, NEW YORK, NY 10038 TEL: 212-608-8840 FAX: 212-608-8039 E-FAX: 917-591-9525 E-MAIL: BZS@BZSLAW.COM Associates Partners Steven Bamundo Ben Bartolotta Michael C. Zwal *Michael O'Beirne James R. Schermerhorn **Edward W. Chen James M. Caffrey Pavlo Paviatos Bartholomew T. Russo BrianS. Lent Alex Kheyman Kat Januszkiewicz *Admittedin NJ **Admittedin NJ & DC October 2, 2019 Ami Morgenstern, Esq. Attorney at Law, PLLC 2nd 40-17 Broadway, Fl. P.O. Box 3223 Long Island City, New York 11103-0223 Re: Abel Hernandez v. Claudio Garcia and Quest Bam April 2016, LLC Our file no.: GLI 7203 Dear Counselors: As you are aware, we are the attorneys who represeñt the Defendants, Claudio Garcia and Quest Bam April 2016, LLC, relative to the above-mentioned matter. On August 20, 2019, this office served upon you our Verified Answer, along with various discovery demands, including, but not limited to our Demand for a Verified Bill of Particulars. To date, we have not received responses to our demands. Therefore, kindly consider this faith" letter our "good attempt to obtain plaintiff's compliance. Please serve responses to our demands within the next fourteen (14) days. or we will have no alternative, but to request the Court's intervention. Very truly yours, BAMUND ZWAL & SCHERMERHORN, LLP r . t,Esq. BSL/ce ADDITIONAL OFFICE: 160 SOUTH CENTRAL AVENUE ELMSFORD, NY 10523