retum’ date of September 11, 2007, and subpoenas for two NES employees, Eric Gany and Harry Beller. if you will not be representing Messrs. Gany and Beller, please let me know. First, as [mentioned in my earlier correspondence, a properly executed declaration from the Custodian of Records is needed, and

bound by New York’s proof of service filing requirement nor New York’s “completion” date in determining when Defendant’s answer needed to be filed. Beller & Keller v. Tyler, 120 F.3d 21, 25-26 (2d Cir. 1997) (reconciling the deadlines imposed by Rule 12(a) and N.Y. C.P.L.R. § 308). Instead, once Defend

y has always accommodated his religious commitments, on occasion permitting pressing Friday transactions to take place on the following Monday. Mr. Beller also told of Jeffrey's assistance in making available any of his contacts in the medical field and to take any necessary time off when one of his s