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Evidence of Levoritz' avoidance of due process and later on he will be rewarded by Fasone for doing so
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THE LAW OFFICES OF DANIEL A. SINGER PLLC245 FIFTH AVENUE, SUITE 1902NEW YORK, NEW YORK 10016
TEL: (212) 569-7853FAX: (212) 683-8332
September 23, 2009
By Fax Transmission(718)Mr. Yonatan S. Levoritz, Esq.The Law Office of YonatanS. Levoritz, P.C.Brooklyn, NY 11223
Re: Svenson v. KrichevskyDocket No: P-28901-08
Dear Mr. Levoritz:
I am in receipt of your letter dated September 21, 2009.
Your purported desire to "move this matter along" has not been backed up byyour actions in this case. The combination of frivolous motions and unauthorizedsubpoenas which have been generated by your office has severely impeded the progressof this action to the detriment of both parties.
With respect to the deposition of Elena Svenson, you were advised by Notice ofDeposition that said deposition would be conducted on September 22, 2009 at 10:00 AMat my office. Almost immediately upon receipt of such notice, you confirmed that bothyou and Ms Svenson would be attending, requesting only that the deposition of Ms.Svenson take place in Kings County rather than New York County. While I was under nolegal duty to do so, I thereafter advised you that you that I had moved the place ofdeposition to Kings County and provided you with the address where the depositionwould take place. Less than twenty four (24) hours before the deposition was scheduledto commence, I received your fax regarding your so-called on engagements on September22 d . Your attempt to thereafter reschedule your client's deposition for September 23raand 24th is ludicrous given your short notice of cancellation.
Mr. Yonatan S. Levoritz, Esq.September 22, 2009Page 2 of 2
We are available to conduct the deposition of your client in the afternoon ofOctober 2, 2009, to continue on October 5, 2009. Please advise if those dates areacceptable to you and your client.
You never confirmed the deposition of my client which you noticed forSeptember 25, 2009. Therefore, I assume that you do not intend to move forward at thattime. Regardless, both my client and I have previous engagements which prevent us forbeing present on that date. If you do intend to move forward with the deposition of myclient, please provide me with proposed dates for such deposition and I will confer withmy client regarding availability.
Very truly yours,
Daniel A. Singer
To: Mr. Yonatan S. Levoritz, Esq. THE LAW OFFICES OF DANIEL A.SINGER PLLC245 FIFTH AVENUE, SUITE 1902NEW YORK, NEW YORK 10016TEL: (212) 569-7853FAX: (212) 683-8332dan(&,dasingerlaw.corn
Fax: (718) 942-4152
Date: 9/24/2009
Regarding: Svenson. V. KrichevskyFamily Court Index No. 142040
Pages: 3
Comments:
Please see attached.