`NYSCEF DOC. NO. 155
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`INDEX NO. 802966/2020
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`RECEIVED NYSCEF: 11/11/2021
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`VIA NYSCEF & EMAIL
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`November 11, 2021
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`John P. Comerford Esq.
`Lipsitz, Ponterio & Comerford, LLC
`424 Main Street, Suite 1500
`Buffalo, NY 14202
`
`Re: Robert J. Ratajczak, as Executor of th Estate of Felix Ratajczak, Deceased, v. AII
`Acquisition, LLC, f/k/a AII Acquisition CORP. f/k/a Athlone Industries, INC. f/k/a
`Holland Furnace Company, et al.
`Index No. 802966/2020 (New York Supreme Court, Erie County)
`Burnham LLC's Pre-Trial Disclosures
`
`Clyde & Co US LLP
`The Chrysler Building
`405 Lexington Avenue, 16th Floor
`New York, New York 10174
`United States
`www.clydeco.com
`
`Aubree.Winkler@clydeco.us
`Direct Line: +1 816 424 8061
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`Dear Mr. Comerford:
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`On behalf of the Defendant, Burnham LLC, in the above referenced matter, we hereby
`serve the following:
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`1. Burnham LLC's Fact Witness List;
`2. Burnham LLC's Exhibit List;
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`We reserve the right to supplement, amend, or otherwise modify these pre-trial
`disclosures. Should any defense counsel desire the above documents, please contact the
`undersigned.
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`Sincerely,
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`Aubree Winkler
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`Enclosures
`Cc: All Remaining Defense Counsel- w/o encl. via NYSCEF.
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`Clyde & Co US LLP is a Delaware limited liability partnership with offices in
`Atlanta, Chicago, Miami, New Jersey, New York, Newport Beach, San Francisco and Washington D.C.
`Clyde & Co US LLP is affiliated with Clyde & Co LLP, a limited liability partnership registered in England and Wales.
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