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THE LAW OFFICES OF DANIEL A. SINGER PLLC 245 FIFTH AVENUE, SUITE 1902 NEW YORK, NEW YORK 10016 TEL: (212) 569-7853 FAX: (212) 683-8332

By Fax Transmission

(718)

Mr. Yonatan S. Levoritz, Esq. The Law Office of Yonatan S. Levoritz, P.C. Brooklyn, NY 11223

September 23, 2009

Dear Mr. Levoritz:

Re:

Svenson v. Krichevsky Docket No: P-28901-08

I am in receipt of your letter dated September 21, 2009.

Your purported desire to "move this matter along" has not been backed up by your actions in this case. The combination of frivolous motions and unauthorized subpoenas which have been generated by your office has severely impeded the progress of this action to the detriment of both parties.

With respect to the deposition of Elena Svenson, you were advised by Notice of Deposition that said deposition would be conducted on September 22, 2009 at 10:00 AM at my office. Almost immediately upon receipt of such notice, you confirmed that both you 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 no legal duty to do so, I thereafter advised you that you that I had moved the place of deposition to Kings County and provided you with the address where the deposition would take place. Less than twenty four (24) hours before the deposition was scheduled to commence, I received your fax regarding your so-called on engagements on September 22 d . Your attempt to thereafter reschedule your client's deposition for September 23ra and 24 th is ludicrous given your short notice of cancellation.

Mr. Yonatan S. Levoritz, Esq. September 22, 2009 Page 2 of 2

We are available to conduct the deposition of your client in the afternoon of October 2, 2009, to continue on October 5, 2009. Please advise if those dates are acceptable to you and your client.

You never confirmed the deposition of my client which you noticed for September 25, 2009. Therefore, I assume that you do not intend to move forward at that time. Regardless, both my client and I have previous engagements which prevent us for being present on that date. If you do intend to move forward with the deposition of my client, please provide me with proposed dates for such deposition and I will confer with my client regarding availability.

Very truly yours,

Daniel A. Singer

To: Mr. Yonatan S. Levoritz, Esq.

THE LAW OFFICES OF DANIEL A. SINGER PLLC 245 FIFTH AVENUE, SUITE 1902 NEW YORK, NEW YORK 10016

Fax: (718) 942-4152

TEL: (212) 569-7853 FAX: (212) 683-8332 dan(&,dasingerlaw.corn

Date: 9/24/2009

 

Regarding: Svenson. V. Krichevsky Family Court Index No. 142040

Pages: 3

Comments:

Please see attached.

HP LaserJet M2727nf MFP

Fax Confirmation Report

HP LASERJET FAX (212) 683-8332 Sep-24-2009 12:11AM

Job Date

62

9/24/2009

Time

Type

12:10:14AM Send

Identification

17189424152

Duration

1:05

Pages

3

Result

OK