Sent from my iPhone

Begin forwarded message:

From: James Donovan <jdonova1@rochester.rr.com>

Date: March 20, 2024 at 3:20:11 PM EDT
To: corvair19652@icloud.com
Subject: Smith Divorce update
Reply-To: James Donovan <jdonova1@rochester.rr.com>

James P. Donovan
CFS
585.752.5950

-----------------------------------------

From: "Heidi Feinberg"

To: "Althea Merryman", "jdonova1@rochester.rr.com"
Cc:
Sent: Wednesday March 13 2024 5:30:52PM
Subject: Fw: Smith Divorce update

Here's a thread about the latest plan with Robbin to respond to your email of Saturday.

Thanks. Talk soon.

H.
_______

From: Heidi Feinberg <heidi@dukelawfirm.com>

Sent: Wednesday, March 13, 2024 1:10 PM
To: Gary Freedman <garyfreedman92@gmail.com>
Cc: Althea Merryman <althea@dukelawfirm.com>;
SmithRobbinDivorceZ11569251@dukelawfirm.filevineapp.com
<SmithRobbinDivorceZ11569251@dukelawfirm.filevineapp.com>
Subject: Re: Smith Divorce update

Let's see what she does tomorrow.

If she pays and promises to sign the agreement I prepare, I will let you know. Can you have Bob get updated
account statements of what's on hand in the real estate attorney's escrow account (Rabideau) and the joint
investment accounts we have been discussing in letters and emails that we are using for taxes, expenses,
bills, etc.?

Please note that Robbin discharged Jim Donovan - the accountant we were using to help us, and he was
doing a lot to help her prepare the 2022 income tax return. If she does as I've asked by tomorrow, I will ask
her to please use Jim to get the 2022 tax returns done. If she won't, however, Bob may want to step up and
handle it again like he did for years.

Deer Park closed. I haven't seen a closing statement yet. If Bob could get his hands on it and provide it to us
that would be helpful. I don't know what the status of the 31 Main Street closing is, so again, to the extent he
can take charge to keep the deal going, he should.

But all of this is for after tomorrow. Again, I'm not sure Robbin will meet the deadlines I set, and if I don't have
what I need tomorrow, I have to make the motion. Quite frankly, I should have made it months ago. I'll be in
touch.

Best,
Heidi

Heidi Feinberg, Esq.

Attorney at Law
heidi@dukelawfirm.net
Phone: 585-346-3220

[www.dukelawfirm.net]w
ww.dukelawfirm.net
robbin%20smith1250062a0f131da18573e22619

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From: Gary Freedman <garyfreedman92@gmail.com>

Sent: Wednesday, March 13, 2024 9:32 AM
To: Heidi Feinberg <heidi@dukelawfirm.com>
Subject: Re: Smith Divorce update

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Hi Heidi,

Thanks for the update. I did send you the counter and I am baffled. I'll go
back and take a look.

Gary M. Freedman, Esq.

300 72nd Street
Niagara Falls, New York 14304
716-512-2499
garyfreedman92@gmail.com

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On Tue, Mar 12, 2024 at 7:22 PM Heidi Feinberg <heidi@dukelawfirm.com>

wrote:
Gary - I'm giving Robbin until Thursday to pay off her invoices and give me something in writing
promising to sign the settlement agreement I will prepare for her.

If she does that, I will draft the PSA with the terms outlined in the attached letter. I'll send you an
agreement for Bob to sign early next week. I never received his response or counter to the
attached letter.

Please relay to Bob that I don't yet have her commitment to the terms set forth in this letter, so if he
wants substantial changes and negotiating, we are not going to settle this, and I will move to get off
the case. I'm not confident she will agree to my conditions to continue representing her, and as it
is, we are about 3 weeks away from the entire case getting dismissed and both parties having to
start all over again from scratch.

Therefore, if she hasn't done as directed by Thursday, I will file a motion to withdraw and vacate the
60-day order, and you'll get a copy of that early next week instead of a PSA to sign.

Oi vey.

Hope you are well.

H.

Heidi Feinberg, Esq.

Attorney at Law
heidi@dukelawfirm.net
Phone: 585-346-3220

www.dukelawfirm.net

robbin%20smith1250a2ec5e38d06b705829570a

Livingston County/ Lakeville Office:

3407 Rochester Road
Lakeville, NY 14480

Monroe County/ Brighton Office:

780 Blossom Road, Lower Level, East Suite
Brighton, New York 14610

Both offices are by appointment only.

To schedule your consultation now, please use this link: SCHEDULE YOUR APPOINTMENT
HERE!
Clients who have a current, active case with us may use this scheduling link: CURRENT
CLIENT APPOINTMENTS

Privileged Communications
This communication is not intended as legal advice, and no attorney-client relationship results from
this email (only clients who have signed a retainer agreement are considered to have an attorney-
client relationship with the firm). E-mails sent by Duke Law Firm, P.C. are intended only for the use
of the individual or entity to whom it is addressed and may contain information that is privileged,
confidential and exempt from disclosure under applicable law. If the reader is not the intended
recipient or the employee or agent responsible for delivering the message to the intended recipient,
it is hereby notified that any dissemination, distribution or copying of the communication is strictly
prohibited. If you receive a communication in error, please notify the sender of the communication
immediately.