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Richard Thompson v. Kujawski & Kujawski, PLLC et al

Docket 600375/2021, New York State, Suffolk County, Supreme Court (Jan. 8, 2021)
Joseph A Santorelli, presiding
Case TypeTorts - Other Professional Malpractice (Legal Malpractice)
TagsTort, Civil, Other, Professional Malpractice, Malpractice, Legal Malpractice
Plaintiff - Petitioner Richard Thompson
Defendant - Respondent Kujawski & Kujawski, PLLC
Defendant - Respondent Kujawski & Kujawski, Esqs.
...
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ORDER - PRELIMINARY CONFERENCE

Document Richard Thompson v. Kujawski & Kujawski, PLLC et al, 600375/2021, 14 (N.Y. Sup. Ct., Suffolk County Feb. 3, 2022)
O) Authbrlzauons tur gamifl(E)'pnploymed records ru;bhsd on or b€torc Zlr'llwP - shall be liattr. or'dra opposlng hr ihe 1 of 3 iIrcr &P.+.k- lA*-rh 6hall nonethila6s pfs3orysd. addrosses d all ll none, povtdb L 2i-19 to o[ t? 2Dl6 ? i i 1 l l l 1 l i lI ...
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PRELIMINARY CONFERENCE ORDER (PROPOSED)

Document Richard Thompson v. Kujawski & Kujawski, PLLC et al, 600375/2021, 13 (N.Y. Sup. Ct., Suffolk County Jan. 13, 2022)
It is 6~r$b.t $TJPULATEQ and OROE~e.ti: /· ' .. lli~ Within Actfo" Is herCtby·dealgna~ed as trrANOAR() and thus subject to the 12 month dlaciO.ure · tl~ limitations period applicable thereto (22 NYCRR 202.19).
· g. (\CC!dentre o prepared in the regular course of business shalf be exchanged pursuanfto CPLR 3101 (g) b .
_End'Q~&te for All Oiscl(')sure, other ihao expert disclosure, shall be held on _______ _ .. 10._ experfOisclosur& shall be provided by all parties pursuant to CP.LR 310.1.
!SShall ensure tha·~ a Stipulation of Olsccintlnuance shall be .promptly filed if the case settles before· the nexl rne~ilng with the Court · · · ·.
Failure to comply wUh a~y;olthese directions may result in lhe imposition of costs or sanctions or other authorized by law •.. ·· · · · · · · · · ·· · · · ·.
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COURT NOTICE

Document Richard Thompson v. Kujawski & Kujawski, PLLC et al, 600375/2021, 12 (N.Y. Sup. Ct., Suffolk County Jan. 13, 2022)
Index No. 600375/2021 Richard Thompson - v. - Kujawski & Kujawski, PLLC et al
This action is scheduled for a preliminary conference on: January 27, 2022 Please notify all parties.
Please refer to nycourts.gov 10th Judicial Districts Suffolk Supreme Courts homepage for the rules and the blank order to be filled out and uploaded to NYSCEF before the scheduled Preliminary Conference date.
Thank you
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ANSWER

Document Richard Thompson v. Kujawski & Kujawski, PLLC et al, 600375/2021, 5 (N.Y. Sup. Ct., Suffolk County Mar. 1, 2021)
To the extent that any response is required, defendants deny all allegations of wrongdoing set forth in paragraph “5” of the Verified Complaint, and respectfully refer all questions of law to the Court.
Deny each and every allegation set forth in paragraph “19” of the Verified Complaint, except admit that defendant Mark Kujawski spoke with plaintiff on the telephone on or about October 2, 2017, concerning the underlying personal injury matter.
To the extent that any response is required, defendants deny all allegations of wrongdoing set forth in paragraph “44” of the Verified Complaint, and respectfully refer all questions of law to the Court.
To the extent that any response is required, defendants deny all allegations of wrongdoing set forth in paragraph “45” of the Verified Complaint, and respectfully refer all questions of law to the Court.
and MARK C. KUJAWSKI, ESQ., demand judgment dismissing the verified complaint herein with prejudice, awarding costs, disbursements and reasonable counsel fees, and granting such other and further relief as the Court deems just and proper.
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SUMMONS + COMPLAINT

Document Richard Thompson v. Kujawski & Kujawski, PLLC et al, 600375/2021, 1 (N.Y. Sup. Ct., Suffolk County Jan. 8, 2021)
On May 27, 2014 Thompscñ hired DaSndanta and MK and signed a legal retainer agreement, whereby the Defendant would represent Thompson and commence a lawsuit in Suffolk Supreme Court seeking damages against Griffin.
On June 2017, MK advised 21, Thompson that Defendant and Griffin's attorneys were discussiñg mediation and/or arbitration and the possibility of a bifercated trial with
On or about September 15, 2017, MK had sent Thompson a text message stating, "Allstate has agreed to concede liability and do a s===ay jury trial on your case for the full policy.
Said explanation does not contain an adequate description of Thompson's right of appeal (or lack thereof) or his inability to call an expert witness to testify on his behalf or the S-----y Jury Trial part rules regarding the same.
Thompson attempted to discuss this with MK but MK was preoccupied preparing for a "Wrongful Death" trial he purportedly had scheduled the next day in the same courthouse.
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PRELIMINARY CONFERENCE REQUEST

Document Richard Thompson v. Kujawski & Kujawski, PLLC et al, 600375/2021, 10 (N.Y. Sup. Ct., Suffolk County Sep. 9, 2021)
the State of age, I am not a party to the action, and I reside in Nassau County in served
true copy the of same of by mailing official depository last known address(es) annexed the a sealed in envelope, the
Notary Public, State of New York Reg. No. 01HA6411464 Qualified in Sugolk County Commission Expires Nav6iiiber 23, 20
are not document(s) admitted duly and reasonable to practice inquiry, of New York law in the courts State, the contentions contained in the above certifies referenced that,
office of the within that is a (certified) named the clerk of the within true copy of a duly entered in the court on
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RJI -RE: REQUEST FOR PRELIMINARY CONFERENCE

Document Richard Thompson v. Kujawski & Kujawski, PLLC et al, 600375/2021, 11 (N.Y. Sup. Ct., Suffolk County Sep. 9, 2021)
If none, leave blank.
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