From: Fried, William Sent: Monday, June 11, 2018 10:43 AM To: Kevin A. Fritz <kaf@msf-law.com>; Christopher Gorman <CGorman@Abramslaw.com> Cc: Stephen B. Meister <sbm@msf law.com>; Poddar, Shivani ' <MPetrocelli@Abramslaw.com>; Subject: RE: PSB Indian Creek et al vs Halpern et al Kevin My recollection is that Steve told Judge Scarpulla that he would discontinue the Florida IC action as long as we agreed not to use that as an argument to dismiss the lis pendens. If you are no longer willing to do that, then that is certainly your right. However, the Judge wanted us to get back to you quickly which we did. William R. Fried Partner Herrick, Feinstein LLP Two Park Avenue New York, NY 10016 212.592.1684 Office WFried@herrick.com website bio Sent: Monday, June 11, 2018 10:39 AM 1
Cc: Fried, William <wfried@herrick.com>; Stephen B. Meister <sbm@msf-law.com>; Poddar, Shivani <MPetrocelli@Abramslaw.com>; Are you referring to settlement discussions that Halpern backed out of? On Jun 11, 2018, at 10:35 AM, Christopher Gorman <CGorman@Abramslaw.com> wrote: I'm not referring to Collins. Please let me know what happened to your offer that you would discontinue the Florida/Indian Creek litigation without prejudice. MRAM UENWERMW UENsrEnnsN, EisuAN, FonMtro, UERum wati & caanne, LLP Tel: 516-328-2300 x273 I Fax: 516-328-6638 W K~. Lake Success, New York 11042 Emad: CGorman@Abramslaw.com LongIsland Manhattan Broaldyn Rochester (516)328-2300 (212)279-9200 (718)215-5300 (585)218-9999 CONFIDENTIAUTYNOTICE:This e-mail may be an attorney-client communication and may contain information that is privileged and confidential and is therefore subject to legal restrictions and penalties regarding its unauthorized disclosure or other use. If you are not......... Sent: Monday, June 11, 2018 10:33 AM Cc: Fried, William <wfried@herrick.com>; Stephen B. Meister <sbm@msf-law.com>; Poddar, Shivani <MPetrocelli@Abramslaw.com>; You are referring to Collins. We have a LP filed in the Indian Creek case in FL. Who is representing the defendants in that case? On Jun 11, 2018, at 10:29 AM, Christopher Gorman <CGorman@Abramslaw.com> wrote: What happened to your offer to discontinue without prejudiced' 2
<image00e97b.jpg> Tel: 516-328-2300 x273 <imaged7c8ac.jpg> Fax: 516-328-6638. Email: CGorman@Abramslaw.com <imagee725a3.jpg> Lake Success, New York 11042 CONFIDENTIAUTYNOTICE:This e-mail may be an attorney-client communication and may contain information that is privileged and confidential and is therefore subject to legal restrictions and penalties regarding its unauthorized disclosure or other use. If you are not Sent: Monday, June 11, 2018 10:28 AM Cc: Fried, William <wfried@herrick.com>; Stephen B. Meister <sbm@msf-law.com>; Poddar, Shivani <MPetrocelli@Abramslaw.com>; Chris: Please let us know who is representing the defendants in the Indian Creek action filed in Florida. We are going to propose that such case is stayed pending Justice Scarpulla's ruling on the MTDs and, depending on the outcome, any appeal therefrom. On Jun 7, 2018, at 10:38 AM, Christopher Gorman <CGorman@Abramslaw.com> wrote: What is the status of this stipulation? <image821f2f.jpg> Tel: 516-328-2300 x273 <image192b78.jpg> Fax: 516-328-6638. Email: CGorman@Abramslaw.com <imagea9495e.jpg> Lake Success, New York 11042 CONFIDENTIALITYNoTICE: This e-mail may be an attorney-client communication and may contain information that is privileged and confidential and is therefore subject to legal restrictions and penalties regarding its unauthorized disclosure or other use. if you are not From: Christopher Gorman Sent: Monday, June 04, 2018 1:13 PM To: 'Kevin A. Fritz' <kaf@msf-law.com>; Fried, William <wfried@herrick.com> Cc: Stephen B. Meister <sbm@msf-law.com>; Poddar, Shivani 3
<MPetrocelli@Abramslaw.com> Subject: RE: PSB Indian Creek et al vs Halpern et al We consent to the discontinuance of the recently commenced Florida litigation involving Indian Creek. Please send us a stipulation of discontinuance with the language you would like included regarding the conditions for the discontinuance so that we can review. From: Kevin A. Fritz [mailto:kaf@msf-law.coml Sent: Thursday, May 31, 2018 10:45 AM To: Fried, William <wfried@herrick.com>; Christopher Gorman <CGorman@Abramslaw.com> Cc: Stephen B. Meister <sbm@msf-law.com>; Poddar, Shivani <MPetrocelli@Abramslaw.com> Subject: PSB Indian Creek et al vs Halpern et al In compliance with the Court's directive, we want to report back to the Court on Bill's suggestion to move the Collins claims to Florida. The Part Clerk confirmed that the judge is available right now for a call. Is everyone available? MSF Meister Seelig & Fein LLP Kevin A. Fritz Partner 125 Park Avenue 7th FlOOr New York, NY 10017 Direct (212) 655-3570 Firm (212) 655-3500 Fax (212) 655-3535 kaf@msf-law.com New York New Jersey Connecticut C_alifornia Website IMPORTANT NOTICES: NOTICE UNDER E-SIGN ACT: Unless specifically set forth herein, the transmission of this communication is not intended to be a legally binding electronic signature, and no offer, commitment or assent on behalf of the sender or its client is expressed or implied by the sending of this facsimile, or any attachments hereto. NOTICE OF ATTORNEY'5 CONFIDENTIALITY: The material submitted herewith contains, and is intended to be a confidential transmission of information or documents from MElsTER SEELIG at FEIN LLP which is legally privileged. The materials or information enclosed are intended only for the use of the individual or entity named in this transmission sheet. if you are not the intended recipient, any disclosure, copying, distribution or the taking of any action in reliance on the contents of this transmission is strictly prohibited. If you have received this telecopy transmission in error, please notify us by telephone immediately, so that we can arrange for the return of the original documents to us at our cost. IRS CIRCULAR 230 DISCLOsURE: As required by U.s. Treasury Regulations governing tax practice, you are hereby advised that any written tax advice contained herein was not written or intended to be used (and cannot be used) by any taxpayer for the purpose of avoiding penalties that may be imposed under the U.S. Internal Revenue Code.