EXHIBIT(S) - 1 (Motion #3) - January 16, 2023 Email to Opposing Counsel

On October 8, 2021 a torts - other (defamation) case was filed by Sean Dugan, represented by Aulivola, Michelle, Bohler, Nicole Lynn, and Szalkiewicz, Daniel S, against Anthony Berini, represented by Cilento, Michael Dominick, and Lin, David Dong Ann, in the jurisdiction of Kings County. Judge Lisa S. Ottley presiding.

                        
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FILED: KINGS COUNTY CLERK 01/24/2024 11:17 AM INDEX NO. 525698/2021 Daniel Szalkiewicz NYSCEF DOC. NO. & Associates, 59 P.C. Mail - Re: Dugan v. Berini 525698/2021 RECEIVED NYSCEF: 1/22/24, 9:44 AM 01/24/2024 Daniel Szalkiewicz Re: Dugan v. Berini 525698/2021 1 message Daniel Szalkiewicz Mon, Jan 16, 2023 at 12:06 PM To: Mike Cilento Cc: David Lin Mike, It is my understanding that as a matter of law, I am required to file the proposed amended complaint. It was not done …

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