Preview
FILED: NEW YORK COUNTY CLERK 05/08/2020 12:13 PM INDEX NO. 157343/2019
NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 05/08/2020
BAMUNDO ZWAL
&SCHERMERHORNtte
LA W 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
Partners Asso ciates
Steven Bamundo Ben Bartolotta
Michael C. Zwal *Michael O'Beirne
James R. Schermerhorn **Edward W. Chen
James M. Caffrey Pavlo Pavlatos
Bartholomew T. Russo BrianS. Lent
Alex Kheyman
Kat Januszkiewicz
*Admittedin NJ
**Admittedin NJ & DC
October 21, 2019
Ami Morgenstern, Esq.
Attorney at Law, PLLC
2nd
40-17 Broadway,
P.O. Box 3223
Long Island City, New York 11103-0223
Re: Abel Hernandez v. C!andie Garcia and Quest Bam April 2016, LLC
Our fileno.: GLI 7203
Dear Counselors:
. As you are aware, we are the attorneys who represent the Defendants, Claudio Garcia and
Quest Bam April 2016, LLC, relative to the above-mentioned matter.
faith"
On October 2, 2019, we wrote to you in "good requesting that you respond to the
various demands, including, but not limited to our Demand for a Verified Bill of Particulars
which were served upon you on August 20, 2019.
To date, we have not received responses to our demands. Therefore, kindly consider this
faith"
letter our final "good attempt to obtain plaintiff's compliance. Please serve responses to
our demands within the next ten (10) business days upon receipt of this letter, or we will
seek intervention from the Court.
We look forward to your prompt response. Thank you.
Very truly yours,
BAMUND ZWAL & SCHERMERHORN, LLP
Bri
BSL/cc
Enclosure:
ADDITIONAL OFFICE:
160 SOUTH CENTRAL AVENUE ELMSFORD, NY 10523
FILED: NEW YORK COUNTY CLERK 05/08/2020 12:13 PM INDEX NO. 157343/2019
NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 05/08/2020
BAMUNDO ZWAL
s &SCHERMERHORN
L AW O F F I C ES
111 JOHN STREET, SUrrE 1100, NEW YORK, NY 10038
.. TEL: 212-608-8840 FAX: 212-608-8039 E-FAX: 917-591-9525
hers -MAIL: BZS@BZSLAW.COM Amodata
Steven Bamundo Ben Bartolotta
Michael C. Zwal *Michael O'Beirne
.JamesR. Schermerhorn **Edward W. Chen
James M. Caffrey Pavlo Pavlatos
Bartholomew T. Russo Brian S. Lent
AlexKheyman
Kat Januszkiewicz
*Admittedin NJ
**A&|sittedin 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 represent the Defandants, 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, in-studing, 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" compH==v
letter our "good attempt to obtain plaintiff's 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
. t,Esq.
BSL/ce
ADDmONAL OmCE:
I 60 SOUTH CENrRAL AVENUE ELMSFORD, NY 19523
Preview
FILED: NEW YORK COUNTY CLERK 05/08/2020 12:13 PM INDEX NO. 157343/2019 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 05/08/2020 BAMUNDO ZWAL &SCHERMERHORNtte LA W 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 Partners Asso ciates Steven Bamundo Ben Bartolotta Michael C. Zwal *Michael O'Beirne James R. Schermerhorn **Edward W. Chen James M. Caffrey Pavlo Pavlatos Bartholomew T. Russo BrianS. Lent Alex Kheyman Kat Januszkiewicz *Admittedin NJ **Admittedin NJ & DC October 21, 2019 Ami Morgenstern, Esq. Attorney at Law, PLLC 2nd 40-17 Broadway, P.O. Box 3223 Long Island City, New York 11103-0223 Re: Abel Hernandez v. C!andie Garcia and Quest Bam April 2016, LLC Our fileno.: GLI 7203 Dear Counselors: . As you are aware, we are the attorneys who represent the Defendants, Claudio Garcia and Quest Bam April 2016, LLC, relative to the above-mentioned matter. faith" On October 2, 2019, we wrote to you in "good requesting that you respond to the various demands, including, but not limited to our Demand for a Verified Bill of Particulars which were served upon you on August 20, 2019. To date, we have not received responses to our demands. Therefore, kindly consider this faith" letter our final "good attempt to obtain plaintiff's compliance. Please serve responses to our demands within the next ten (10) business days upon receipt of this letter, or we will seek intervention from the Court. We look forward to your prompt response. Thank you. Very truly yours, BAMUND ZWAL & SCHERMERHORN, LLP Bri BSL/cc Enclosure: ADDITIONAL OFFICE: 160 SOUTH CENTRAL AVENUE ELMSFORD, NY 10523 FILED: NEW YORK COUNTY CLERK 05/08/2020 12:13 PM INDEX NO. 157343/2019 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 05/08/2020 BAMUNDO ZWAL s &SCHERMERHORN L AW O F F I C ES 111 JOHN STREET, SUrrE 1100, NEW YORK, NY 10038 .. TEL: 212-608-8840 FAX: 212-608-8039 E-FAX: 917-591-9525 hers -MAIL: BZS@BZSLAW.COM Amodata Steven Bamundo Ben Bartolotta Michael C. Zwal *Michael O'Beirne .JamesR. Schermerhorn **Edward W. Chen James M. Caffrey Pavlo Pavlatos Bartholomew T. Russo Brian S. Lent AlexKheyman Kat Januszkiewicz *Admittedin NJ **A&|sittedin 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 represent the Defandants, 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, in-studing, 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" compH==v letter our "good attempt to obtain plaintiff's 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 . t,Esq. BSL/ce ADDmONAL OmCE: I 60 SOUTH CENrRAL AVENUE ELMSFORD, NY 19523