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Exhibit FILED: NEW YORK COUNTY CLERK 04/12/2016 12:36 PM INDEX NO. 159759/2014 NYSCEF DOC. NO. 53 RECEIVED NYSCEF: 04/12/2016
Exhibit
FILED: NEW YORK COUNTY CLERK 04/12/2016 12:36 PM INDEX NO. 159759/2014
NYSCEF DOC. NO. 53 RECEIVED NYSCEF: 04/12/2016
IRvINE OrrIcc2505 MCC*nt W*y, Suitc 100
IRVINE, CALIFORNIA 92614TELEPHONE: (949) 252-0550FAcSIMILE: (949) 252-0553
Los Awoctca OrrIac21650 OxHARO STREET, Suitc 300
W000LAND HILLS, CALIFoRNIA 91387TELEpHoNE: (SIB) 224-SOBSFACSIMILE: (BIB) 224-6061
Via Regular Mail & Facsimile (212) 966-9228Law Offices of Rina Milos210 Canal Street# 502New York, New York 10013
Re: Chu & Lee Realty Corp. v. PAG 8, LLCIndex No.: 159759/14Our File No: 424.0567029
Our office represents the defendant in this matter and this letter serves as a goodfaith effort to secure plaintiffs compliance with defendant’s discovery demands inclusive of aDemand for a Verified Bill of Particulars. We outline below the discovery that plaintiff still owesdefendant:
Demand for a Verified Bill of Particulars:
Item 3: Plaintiff needs to provide identify all entities and persons133 Bower>’, New York, New York, from 2004 to the present.
Item 4: Plaintiff needs to provide identify all entities and persons133 Bower>’, New York, New York, from 2004 to the present.
Item 5: Plaintiff needs to identify dates that any entity or personBowery, New York, New York.
Item 6: Plaintiff needs to provide a response to this item.
Item 6: Plaintiff needs to provide a detailed response to this item.
who performed work at
who performed work at
performed work at 133
Item 13: Plaintiff needs to identify the manner in which the defect alleged was discoveredand identify the person(s) and/or entity(ics) that allegedly caused said defect.
LONDON FISCHER LLP59 MAIDEN LANE
NEW YORK, NEW YORK 10038
(212) 972-1000
FACSIMILE: (212) 972-1030
WWW.LOMDONPISCHER.COM
March 24, 2016
Dear Ms. Milos:
Item 15: Plaintiff needs to provide a detailed response to this item regarding the allegeddefects in plaintiff’s response numbered (9).
Item 18: Plaintiff needs to provide a detailed response to this item regarding the allegeddefects in plaintiff’s response numbered (9).
Item 22: Plaintiff needs to provide greater specificity and needs to provide answers to theentire demand made.
Item 23: Plaintiff needs to provide greater specificity and needs to provide answers to theentire demand made.
Item 24: Defendant inadvertently referred to itself as a third-party defendant. Plaintiffneeds to provide a response to the following item:
If a violation of any rule, regulation, ordinance, law or statute is claimed, specificthe particular section of the rule, regulation, ordinance, law or statute that Chu & Lee Realty Corp.will claim the defendant Pag 8, LLC violated, and in what manner the violation caused orcontributed to Chu & Lee Realty Corp.’s damages.
Item 26: Defendant inadvertently referred to itself as a third-party defendant. Plaintiffneeds to provide a response to the following item:
If a violation of any rule, regulation, ordinance, law or statute is claimed, specificthe particular section of the rule, regulation, ordinance, law or statute that Chu & Lee Realty Corp.will claim the defendant Pag 8, LLC violated, and in what manner the violation caused orcontributed to Chu & Lee Realty Corp.’s damages.
Item 29: Plaintiffneeds to provide a response to this item, which is relevant to the discoveryof this matter.
Item 38: Plaintiff needs to provide a response to this item, which is relevant to the discoveryof this matter.
Item 39: Plaintiff needs to provide a response to this item, which is relevant to the discoveryof this matter.
Item 40: Plaintiff needs to provide a response to this item, which is relevant to the discoveryof this matter.
Item 41: Plaintiff needs to provide a response to this item, which is relevant to the discoveryof this matter.
13701 ILONDON ISCflER LLP
Item 44: Plaintiff needs to provide greater specificity and answer whether another personand/or entity informed you, at any time prior to this lawsuit, that the Premises or any of itscomponents, is unsatisfactory.
Item 45: Plaintiff needs to provide greater specificity and needs to fully provide an answerto the demands made.
Item 46: Plaintiff needs to provide greater specificity and answer whether another personand/or entity informed you, at any time prior to this lawsuit, that the Premises or any of itscomponents, were negatively impacted by defendant.
Item 47: Plaintiff needs to provide greater specificity and needs to fully provide an answerto the demands made.
Item 48: Plaintiff needs to provide a response to this item.
Item 51: Plaintiff needs to provide a response to this item, which is relevant to the discoveryof this matter.
Item 52: Plaintiff needs to provide a response to this item, which is relevant to the discoveryof this matter.
Combined Demands:
Item 4: Plaintiff needs to provide responses to these demands.
Please provide responses to the above discovery within two weeks so that we canavoid judicial intervention. Should we not receive responses to the above discovery demands wewill have no alternative but to seek the Court’s assistance.
Please contact me with any questions.
Very truly yours,
LONDON FISCHER LLP
Tracy . WeinsteinTJW:wbr
Lol’woN fl~lflER LLP
LONDON FISCHER LLP59 MAIDEN LANt
Ncw YORK, NEW YORK 10038
nv NC Orrace2505 MCCAUC W.y, SuiTe 100
RVINC, CAL rORN A 92614TELEPHoNe: (949) 252’0550FAcS MILE: (949) asa-ossa
(212) 972.1000FACSIMILE: (212) 972-1030
www.LoNoonFpscHcn.coM
Los ANGELES Orrict21550 Oxn.no Srnrc,, SUITE 300
WOODLAND HILLS, CALIPORNIA 91367TELEPHONE: (ala) 224-6068F’ACSINII.t: (ale) 224-6061
FACSIMILE TRANSMISSION
FROM: Tracy J. Weinstein DATE: March 24,2016
RE: Chu & Lee Realty v. PAG 8 LLC
FILE NO.:
TO:
424.0567029
Person Company Fax NumberLaw Offices of Rina Milos (212) 966-9228
THIS TELEFAX CONSISTS OF 4 PAGES INCLUDtNG THIS PAGE.
• MESSAGE:
Please see attached letter.IIThis message is intended only for the use of the individual or entity to which ills addressed, and may contain infonnation that is privileged, confidential and exemptfrom disclosure under applicable law. If the reader of this message is not the intended recipient, or the employee or agent responsible for delivering the message to theintended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received thiscommunication in error please notify us immediately by telephone and return the original message to us via the U.S postal service. Thank you.
TIMENAMEFAXTELSER. N
03/24/2016 14:49LONDON FISCHER LLP212—972—1830212—972—ieee8R0A53202512
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TRANSMISSION VERIFICATION REPORT
DATE,TIME 03/24 14:49FAX ND. /NAME 12129669229DURATION 00:80:43PAGE(S) 04RESULT OKMODE STANDARD
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