I am a member of the law firm Wilson, Elser, Moskowitz, Edelman & Dicker LLP (“Wilson Elser”), attorneys for the Defendants, KANE STREET SYNAGOGUE (“KSS”), HEDI HRUBY, JILL ROSE, ALAN BELL, LESLIE WILSHER and LISA SMITH (the “Defendants”).

The Sixth Cause of Action for wrongful interference with an employee relationship is dismissed as Plaintiff failed to allege in the Verified Complaint that Defendants had knowledge of her new employment.

The Court denied Motion #2 in part insofar as it dismissed Plaintiff’s claims against Defendants KSS, Hedi Hruby, Jill Rose, Leslie Wilsher and Lisa Smith (the “Dismissed Defendants”) with prejudice.

Undeterred, and in direct contravention of the Court’s prior order, on June 28, 2021, Plaintiff filed the Amended Verified Complaint (the “Amended Complaint”) based on the same operative facts against all of the Defendants and asserted causes of actions which had already been dismissed.

WHEREFORE, for the reasons set forth above and in Defendants’ prior filings, it is respectfully requested that the Motion to Reargue be granted and the Amended Complaint should be dismissed in whole or in part, and the Cross-Motion be denied, together with such other and further relief as this Court deems just and proper.

Medical record and employment authorizations shall be furnished within thirty (30) days of this Order.

Pursuant to CPLR §3212(a), motions for summary judgement shall be made within one hundred twenty (120) daysofthe filing of the Note of Issue or in accordance with the assigned Judge’s part rules.

If discovery disputes arise, parties may contact the assigned Compliance Judge, only, by email to request a virtual conference.

All parties shall disclose in writing the existence of any insurance agreements, including umbrella and/or excess coverage, as described in CPLR §3101(f) within thirty (30) days of this Order.

Counsel and self-representedlitigants are under a continuing obligation to notify the Court as promptly as possible in the event that an action is settled, discontinued or otherwise disposedof, or if a case or motion has become wholly or partially moot, or if a party has died or filed a petition in bankruptcy.

of Yana Rubin, Esq. to be relieved as attorney for defendant Frank Raffaele is granted upon filing of proof of compliance with the following conditions; and it is further

ORDERED that, within 10 days from entry, said attorney shall serve a copy of this order with notice of entry upon its former client at its last known address by certified mail, return receipt requested, and upon the attorneys for all other parties appearing herein by posting to the New York State Courts Electronic Filing System; and it is further

ORDERED that, together with the copy of this order with notice of entry served upon the former client, moving counsel shall forward a notice directing the former client to appoint a substitute attorney within 30 days from the date of the mailing of the notice and the client shall comply therewith, except that, in the event defendant intends instead to represent himself, he shall notify the Clerk of the Part of this decision in writing within said 30-day period; and it is further

Page 1 of 2 ORDERED that any new attorney retained by the defendant shall file a notice of appearance with the Clerk of the General Clerk’s Office (60 Centre Street, Room 119) and the Clerk of the Part within 40 days from the date the notice to retain new counsel is mailed; and it is further

ORDERED that no further proceedings may be taken against the defendant without leave of this court for a period of 40 days after service on the former client of the aforesaid notice to appoint a substitute attorney.

At an IAS Part 92 of the Supreme Court of the State.of New York held in and for the County of Kings at the Courthouselocated at 360 Adams Street, Brooklyn, <====--= New York on the 7th day of February, 2022

Granting such other and further relief as the court deems necessary and proper under the circumstances, and Let personal

it-is-hereby= a copy of upon which it is granted, be and the papers this Order, and by overnight vire-Tñüits made upon the plaintiff,

upon mail en Sarah Fink, Esq., Wilson Elser Moskowitz Edelman & Dicker, LLP, 666-01 eon ord-e2rederreity, NY attorneys for *by telephone or by virtual appearances as directed by the Part 92 Rules defendants

via=N¥-S€EF on or before the 11th day of February , 2022 shall be deemed good and sufficient service.

of YANA RUBIN,ESQ., dated Ll January +7, 2021, and uponall the pleadings heretofore had herein, awh Hoe Plantety o counsel LET DEFENDANT FRANK.

day of —_—_, 2022 at 9:30 AM orassoonthereafter as counsel may be heard, urt 18th February on the whyan Order should not be made and entered:

Pursuant to DR 2-110(C)(1) and (6) granting YANA RUBIN, ESQ. permission to withdraw as counselto the defendants FRANK RAFFAELE

© Staying this matter for not less than ninety (90) days, in orderto allow the defendant, FRANK RAFFAELEthe opportunity to retain new counselto represent him in the place and stead ofYANA RUBIN,ESQ.and (iii)|Granting such other and furtherrelief as the court deems necessary and proper under the circumstances, and SUFFICIENT CAUSE BEING ALLEGED THEREFOR,it is hereby: ORDEREDthat delivery of a copy of this Order, and the papers upon whichit is granted, be personal service & _made uponthe defendant, FRANK RAFFAELEviae--mail, and on Jeff Ruderman, Esq.

attorneys for plaintiff SAHBA SALIMI via NYSCEFonor before the _3rdday, of February _ , 2022 shall be deemed goodandsufficientservice.

UPON READING AND FILING of the Affirmation of YANA RUBIN, ESQ., dated January 17, 2021, and upon all the pleadings heretofore had herein, LET DEFENDANT FRANK RAFFAELE show cause before the Hon.

Richard Latin Court at IAS PART 46 located at 60 Centre Street, Room ___ , New York, NY 10007 on the ______ day of __________, 2022 at 9:30 AM or as soon thereafter as counsel may be heard, why an Order should not be made and entered:

Pursuant to DR 2-110(C)(1) and (6) granting YANA RUBIN, ESQ. permission to withdraw as counsel to the defendants FRANK RAFFAELE

Staying this matter for not less than ninety (90) days, in order to allow the defendant, FRANK RAFFAELE the opportunity to retain new counsel to represent him in the place and stead of YANA RUBIN, ESQ. and (iii) Granting such other and further relief as the court deems necessary and proper under the circumstances, and SUFFICIENT CAUSE BEING ALLEGED THEREFOR, it is hereby: ORDERED that delivery of a copy of this Order, and the papers upon which it is granted, be made upon the defendant, FRANK RAFFAELE via e-mail, and on Jeff Ruderman, Esq.

attorneys for plaintiff SAHBA SALIMI via NYSCEF on or before the _____, _________________ , 2022 shall be deemed good and sufficient service.

UPON READING AND FILING of the Affirmation of YANA RUBIN, ESQ., dated January 17, 2021, and upon all the pleadings heretofore had herein, LET PLAINTIFF JANET KALLO show cause before the Hon.

Carolyn Wade at IAS PART 84 located at 360 Adams Street, Brooklyn, New York on the ______ day of __________, 2022 at 9:30 AM or as soon thereafter as counsel may be heard, why an Order should not be made and entered:

Pursuant to DR 2-110 (A)(2), (C)(5) granting YANA RUBIN, ESQ. permission to withdraw as counsel to the plaintiff, JANET KALLO

Granting such other and further relief as the court deems necessary and proper under the circumstances, and SUFFICIENT CAUSE BEING ALLEGED THEREFOR, it is hereby: ORDERED that delivery of a copy of this Order, and the papers upon which it is granted, be made upon the plaintiff, JANET KALLO via e-mail, and on Sarah Fink, Esq., Wilson Elser Moskowitz Edelman & Dicker, LLP, 666 Old Country Road, Garden City, NY attorneys for

defendants ALAN BELL and KANE STREET SYNAGOGUE via NYSCEF on or before the _____, _________________ , 2022 shall be deemed good and sufficient service.

Before the Court is Defendants’ Motion to Dismiss this Action.

Upon reading the Motion Papers

ROSE, ALAN BELL, LESLIE WILSHER and LISA

filed in connection with Motion Sequence 4, and for good cause shown, the Court Orders that Defendants’ Motion to Dismiss is granted in its entirety.

It is hereby ORDERED that this Action is Dismissed in its entirety, with prejudice.

KANE STREET says I "should consider myself lucky that I am not serving a prison sentence for embezzlement of funds from my employer" and that "after my criminal case was dismissed I chose to file a baseless lawsuit."

Whether you label these payments, "reimbursements," "disbursements" or any other accounting category makes a difference for tax purposes does not change the fact that I did IUl1 steal this money, rather this was my duly earned overtime approved by KANE STREET.

Allegations like "Mr. Bell discovered that Ms. Kallo did not send timesheets she received to Paychex (Memorandum Page 6) will be disproven with discovery in defendants' possession whjch I asked for and djd not recejye.

Instead of exchanging discovery and presenting a case on the merits, defendants are hiding behind frivolous motions and Mr. Bialek's and Ms. Slavina's nasty, offensive and defamatory lies to this Court.

In assessing a motion under CPLR 32ll(a)(7), however, a court may freely consider affidavits submitted by the plaintiff to remedy any defects in the complaint (Rove/lo v. Orofino Rfalty Co., supra, 14p NY2d at 635, 389 NYS2d 314, 351 NE2d 970) and "the erlterlon 11 whether the proponent or the pleadln1 has a eause of aetlon not whether be bas stated one."

When the criminal action was dismissed because the District Attorney reviewed proof that defendants made up the whole story, I decided to sue KANE STREET for all the damage these lies caused me.

LESLIE WILSHER, LISA SMITH, HEDI HRUBY and JILL ROSE were the officers of KANE STREET involved in the crusade against me.

If defendants truly suspected this, they could have simply called the payroll company and confirmed this information to be true before making any statements to law enforcement.

They cornered me, accused me of stealing, threw me out of the office, did not give me a chance to explain, and denied me access to the records which would answer everybody's questions.

The cause of action for wrongful interference with employee relationship was dismissed because "plaintiff failed to allege that defendants had knowledge of her new employment."

SUPREME COURT OF mE STAIE OF NEW YORK COUNlY OF KINGS ------------------x Index No# SlSS91/2019

-against- Hon.

Carolyn Wade

PLEASE TAKE NOTICE that upon the annexed affidavit of JANET KALLO sworn to on the 18* day of April, 2023 and the exhibits annexed thereto, and upon all the pleadings and proceedings had herein, the PLAINTIFF will cross-move this Court located at 360 Adams Street, Brooklyn, New York, Part 84, oo the 11" day of May, 2023 at 10:00 o'clock, or as soon thereafter as can be beard for an Order: Rcarguing the Court's prior order dated 11-17-2020, dismissing KANE STREET SYNAGOGUE, HEDI HRUBY, JILL ROSE, LESLIE WILSHIRE and LISA SMI1H from this action and dismissing causes of action for malicious prosecution, abuse of process, wrongful interference with employer relations, negligent infliction of emotion distress, and for such other and further relief as to this Court may seem just and proper.

Dated: April 17, 2023 From: Janet Kano Isl Plaintiff Pro-Se

TM: Eamngo: Dlductlons; 403- COnlltlUI $500.00.

E--, Pay Poriod $ 101.23, Evety Pay Period

BIOOIJyn.

NY 11230 DocluctloM:

This correspondence will respond to your Notice of Discovery and Inspection, dated December 29, 2022 (the "Demand").

Initially, the Dismissed Defendants object to the Demand to the extent that it is directed at them.

As the Dismissed Defendants are no longer parties to this litigation and as there are no pending claims against them, they are under no obligation, and will not be responding, to the Demand.

Defendant Bell further objects to the Demand on the grounds that it is premature, overly broad, unduly burdensome, not reasonably limited in time or in scope, not reasonably calculated to lead to the discovery of admissible evidence and exceeds the scope of discovery permitted by the CPLR.

Accordingly, please be advised that Defendant Bell will not be providing a further response to the Demand until the motion practice is resolved.

TM: Eamngo: Dlductlons; 403- COnlltlUI $500.00.

E--, Pay Poriod $ 101.23, Evety Pay Period

BIOOIJyn.

NY 11230 DocluctloM: