On September 18, 2023 a
LETTER / CORRESPONDENCE TO JUDGE (Motion #002) - Letter Paul H. Aloe to Honorable Jennifer G. Schecter
was filed
involving a dispute between
Jordan Bardach,
and
Anna Martynova,
Aron Wolocowitz,
Jennifer Milosavljevic,
Rentability, Inc.,
Yoel Hershkowitch,
for Commercial - Other - Commercial Division (N-PCL 618)
in the District Court of New York County.
Preview
Paul H. Aloe • Direct (212) 868-1888 • paloe@kudmanlaw.com
November 3, 2023
VIA NYSCEF ONLY
Honorable Jennifer G. Schecter
Supreme Court of the State of New York
60 Centre Street – Room 228
New York, NY 10007
Re: Bardach v. Martynova, et al.
Supreme Court, New York County Index No. 159110/2023
Motion Seq. No. 002
Dear Justice Schecter:
I represent defendants Anna Martynova, Jennifer Milosavljevic, Yoel Hershkowitch, and
Aron Wolocowitz in the above referenced action. I write in connection with the Affirmation of
Brett G. Canna in Opposition to Rentability’s Order to Show Cause filed in connection with a
motion to disqualify him by Angelyn D. Johnson. This is not my motion that I filed no papers in
connection with it.
I am constrained to write, however, as Paragraph 8 of Mr. Canna’s affirmation (NYSCEF
No. 118) relates to a settlement discussion that he had with me. The recitation, while not accurate,
purports to discuss settlement discussions I had with Mr. Canna towards resolving the overall case.
Those settlement discussions should have not been filed in Court under CPLR 4547. I would ask
the Court to strike paragraph 8 and not consider the content of any settlement discussions that he
had and I have had relative to this motion.
It is difficult to settle litigation when the discussions themselves are improperly used and
filed in court. That makes a successful settlement negotiation impossible.
Respectfully submitted,
Paul H. Aloe
cc: Brett G. Canna, Esq. (via NYSCEF and email)
Angelyn D. Johnson, Esq. (via NYSCEF and email)
Jacob D. Reichman, Esq. (via NYSCEF and email)
488 Madison Avenue • 23rd Floor • New York, NY 10022
www.kudmanlaw.com • Telephone (212) 868-1010
Document Filed Date
November 03, 2023
Case Filing Date
September 18, 2023
Category
Commercial - Other - Commercial Division (N-PCL 618)
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Paul H. Aloe • Direct (212) 868-1888 • paloe@kudmanlaw.com November 3, 2023 VIA NYSCEF ONLY Honorable Jennifer G. Schecter Supreme Court of the State of New York 60 Centre Street – Room 228 New York, NY 10007 Re: Bardach v. Martynova, et al. Supreme Court, New York County Index No. 159110/2023 Motion Seq. No. 002 Dear Justice Schecter: I represent defendants Anna Martynova, Jennifer Milosavljevic, Yoel Hershkowitch, and Aron Wolocowitz in the above referenced action. I write in connection with the Affirmation of Brett G. Canna in Opposition to Rentability’s Order to Show Cause filed in connection with a motion to disqualify him by Angelyn D. Johnson. This is not my motion that I filed no papers in connection with it. I am constrained to write, however, as Paragraph 8 of Mr. Canna’s affirmation (NYSCEF No. 118) relates to a settlement discussion that he had with me. The recitation, while not accurate, purports to discuss settlement discussions I had with Mr. Canna towards resolving the overall case. Those settlement discussions should have not been filed in Court under CPLR 4547. I would ask the Court to strike paragraph 8 and not consider the content of any settlement discussions that he had and I have had relative to this motion. It is difficult to settle litigation when the discussions themselves are improperly used and filed in court. That makes a successful settlement negotiation impossible. Respectfully submitted, Paul H. Aloe cc: Brett G. Canna, Esq. (via NYSCEF and email) Angelyn D. Johnson, Esq. (via NYSCEF and email) Jacob D. Reichman, Esq. (via NYSCEF and email) 488 Madison Avenue • 23rd Floor • New York, NY 10022 www.kudmanlaw.com • Telephone (212) 868-1010