THE LAW OFFICES OF DANIEL A.

SINGER PLLC
245 FIFTH AVENUE, SUITE 1902
NEW YORK, NEW YORK 10016
TEL: (212) 569-7853
FAX: (212) 683-8332

September 23, 2009

By Fax Transmission
(718)
Mr. Yonatan S. Levoritz, Esq.
The Law Office of Yonatan
S. Levoritz, P.C.
Brooklyn, NY 11223

Re: Svenson v. Krichevsky

Docket No: P-28901-08

Dear Mr. Levoritz:

I am in receipt of your letter dated September 21, 2009.

Your purported desire to "move this matter along" has not been backed up by
your actions in this case. The combination of frivolous motions and unauthorized
subpoenas which have been generated by your office has severely impeded the progress
of this action to the detriment of both parties.

With respect to the deposition of Elena Svenson, you were advised by Notice of
Deposition that said deposition would be conducted on September 22, 2009 at 10:00 AM
at my office. Almost immediately upon receipt of such notice, you confirmed that both
you and Ms Svenson would be attending, requesting only that the deposition of Ms.
Svenson take place in Kings County rather than New York County. While I was under no
legal duty to do so, I thereafter advised you that you that I had moved the place of
deposition to Kings County and provided you with the address where the deposition
would take place. Less than twenty four (24) hours before the deposition was scheduled
to commence, I received your fax regarding your so-called on engagements on September
22 d . Your attempt to thereafter reschedule your client's deposition for September 23ra
and 24 th is ludicrous given your short notice of cancellation.
Mr. Yonatan S. Levoritz, Esq.
September 22, 2009
Page 2 of 2

We are available to conduct the deposition of your client in the afternoon of

October 2, 2009, to continue on October 5, 2009. Please advise if those dates are
acceptable to you and your client.

You never confirmed the deposition of my client which you noticed for
September 25, 2009. Therefore, I assume that you do not intend to move forward at that
time. Regardless, both my client and I have previous engagements which prevent us for
being present on that date. If you do intend to move forward with the deposition of my
client, please provide me with proposed dates for such deposition and I will confer with
my client regarding availability.

Very truly yours,

Daniel A. Singer
To: Mr. Yonatan S. Levoritz, Esq.
Fax: (718) 942-4152
THE LAW OFFICES OF DANIEL A.
SINGER PLLC
245 FIFTH AVENUE, SUITE 1902
NEW YORK, NEW YORK 10016
TEL: (212) 569-7853
FAX: (212) 683-8332
dan(&,dasingerlaw.corn

Date: 9/24/2009

Regarding: Svenson. V. Krichevsky

Family Court Index No. 142040

Pages: 3

Comments:
Please see attached.
HP LaserJet M2727nf MFP

Fax Confirmation Report

HP LASERJET FAX
(212) 683-8332
Sep-24-2009 12:11AM

Job Date Time Type Identification Duration Pages Result

62 9/24/2009 12:10:14AM Send 17189424152 1:05 3 OK