FILED: NEW YORK COUNTY CLERK 01/19/ :31 AM INDEX NO /2016 NYSCEF DOC. NO. 198 RECEIVED NYSCEF: 01/19/2018

Transcription

1 Franklin R. Kaiman Attorney at Law November 6, 2017 ATELIER CONSULTING LLC 853 Broadway, Suite 800 New York, New York And 11 Broadway -2"~ -2nd Floor New York, New York Re: SUBPOENA DUCES TECUM SUBPOENA AD TESTIFICADUM The Carlton Group Ltd. v. Property Markets Group Inc, et al Supreme Court, New York County Dear Sir/Madam: On Friday, November 3, 2017, you were served with the enclosed Subpoena Duces Tecum and Subpoena ad Testificadum by delivery to the New York State Secretary of State as your agent for service of process. Service was made on the Secretary of State because (a) the security guard at 853 Broadway advised me that you were no longer at that address and would not allow me to go upstairs to attempt personal service (b) the security guard at 11 Broadway advised me that neither you or George Villar, are not recorded as a tenant in the building and the two tenants of the second floor (the Flatiron School and Dynalink advised me that they did not know you or George Villar). If you will provide me with an actual office address, I will make personal service on you. The Secretary of State will not accept the witness fee due to you for each Subpoena. Dahan 4 Nowick, your attorneys, also would not accept the witness fee due to you and would not advise me as to your actual address. I am therefore enclosing in the envelope addressed to you at (a) 853 Broadway, Check No. 322 in the amount of $18.00 and No. 323 in the amount of $15.00 as the witness fees due you and (b) 11 Broadway Check No. 329 in the amount of $18.00 and No. 330 in the amount of $15.00 as the witness fees due yøa. 8". F " R. Kaiman cc: David R. Taxin, Esq. (with enclosures) 111 Fifth Avenue, 6th Floor EmaihFKaiman@PropertyMG.com Telephone: (212) New York, New York Facsimile: (212)

2 â =.= = â.â â THE CARLTON GROUP, LTD., : â â â X Plaintiff,: -against- : PROPERTY MARKETS GROUP, INC., DYNAMIC QPS DEVELOPMENT, LLC, QPS MEZZ, â " JUDICIAL SUBPOENA AD TESTIFICADUM (Testhnony) and PMG BRICKELL HOLDINOS, LLC, X by GEORGE VILLAR, its Managing Member c/ New York State Secretary of State! i WE COMMAND YOU, that all business and excuses being laid aside, you appear, by George Villar your Managing Member, and attend before a notary public, who is not an attorney or employee of an attorney for any party in this action and who is not a person who would be disqualified to act this action, at the New York or * f 3 give testimony in thi > pay t0 the toy 322 FRANKLtN R. KABMAN ESQ 0540 OPERATING ACCOUNT mem 111 FFrH AVE. 6TH FL (212) NEW YORK, NY gyf gg (ffit/pa. $1/ $ re.qoqo) mrs a F. Failure to col 1 you liable to the pers I Sneak / r~e pp )op P~ )I ) I,PDgql, P g I, P1,6ogP 2I,II¹QP gg,e~poq 4L¹¹PQR I5"~e F S" ~ I" P 03 ~ L2 ~2

3 THE CARLTON GROUP, LTD., : Plaintiff,: -against- :. PROPERTY MARKETS GROUP, INC., ~ DYNAMIC -X QPS DEVELOPMENT, LLC, QPS MEZZ, JUDICIAL SUBPOENA DUCES TECUM ocuments Only) and PMG BRICKELL HOLDINGS, LLC, X c/o New York State Secretary of State WE COMMAND YOU, that all business and excuses being laid aside, you appear at the offices of FRANKUN R. KAIMAN. ::,,,::;:". ESQ osm : 323 OPERATING ACCOUNT. /. /. ",:;:;:,;:;::::: on Novemt. so-nwu 111 FIFTH AVE, 6TH FL (212) NEW YORK, NY the time and place "DEFI j~ i m F~r Fr I ~~ c~~fa~mq MWk dc.~ z&c,-i:. $ <~<< ~ y You may c ) For -cscs Sank copies of all respo1 ) :O 2 L L.0? 9 & 2s:PBOLG O te O Failure to comply witti ttus subpoena is pumstiable as a contempt or Court ana snail make 1

4 THE CARLTON GROUP, LTD., : Plaintiff, : -against- : PROPERTY MARKETS GROUP, INC., DYNAMIC Index No /16 QPS DEVELOPMENT, LLC, QPS ME77 JUDICIAL SUBPOENA DUCES TECUM ocuments Only) and PMG BRICKELL HOLDINGS, LLC, c/o New York State Secretary of State WE COMMAND YOU, that all business and excuses being laid aside, you appear at the offices of FRANKLIN R. KAIMAN, Esq, 111 Fifth Avenue, 6* Floor, New York, New York on November the time and place af( FRANKUN R. KAIMAN ESQ 0800.:.,:;.~i ACCOUIfl 329 OPERATING ACCOUNT anina 111 RFTH AVE. STH FL (212) jg., ]y/y NEW g//p ""/j "" YORK, NY 10008, -.":.;,,"i/ ~~0» DEFINI Qgjyr of ~R1 ~ +...:.. "DEFINI C ~c 0$ /&. /P.oP ll You may com asm / t I copies of all responsi <> Hack Failure to con ear w ctw rss F-6S CG i:0 2 1I I 0 7I 7jl I 2>.880 2I.(I"BQ ILG~»00 E "009 I 25»3II" 2 5» 3il il I 1

5 NYSCEF DOC. NO. 198 RECEIVED NYSCEF: ~IWN~~ 01/19/2018 J X PROPERTY MARKETS GROUP, INC., DYNAMIC QPS DEVELOPMENT, LLC, QPS MEZZ,. JUDICIAL SUBPOENA AD TESTIFICADUM (Testimony) - and PMG BRICKELL HOLDING8, LLC, â â THE CARLTON GROUP, LTD., Plaintiff, -against ! by GEORGE VILLAR, its Managing Member c/ New York State Secretary of State I WE COMMAND YOU, that all business and excuses being laid aside, you appear, by George Villar your Managing Member, and attend before a notary public, who is not an attorney or employee of an attorney for any party in this action and who is not a person who would be disqualified to act as a juror because of interest or because of consanguinity or affinity to any party in this action, at the offices of Franklin R. M R f, New York o es4o FRANKi.tN R. KAH8AN ESQ OPERATING ACCOUNT AVS.arNSt. give testimony in th 111 FIFTH AVE, BTH FL (212¼ NEW YORK, NY smna you liable to the pers Order of $ yegg s Fer ~Sl. ~0 2 I,t,0yci) p> sebqlg 00 I ~~

6 FILED: CLERK 01/19/ :31 AM NYSCEF. DOC. NO. 198 /z g". %/ ;:/ i la V Ql Q O O &f H o.-i INDEX NO /2016 RECEIVED NYSCEF: 01/19/2018

7 FILED: CLERK 01/19/ :31 AM NYSCEF DOC. NO. 198 RECEIVED NYSCEF: 01/19/2018 V % I/I r, ; V O N ra ~ INDEX NO /2016