FILED: NEW YORK COUNTY CLERK 03/11/ :10 PM INDEX NO /2014 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 03/11/2016 EXHIBIT I

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1 FILED: NEW YORK COUNTY CLERK 03/11/ :10 PM INDEX NO /2014 NYSCEF DOC. NO. 45 RECEIVED NYSCEF: 03/11/2016 EXHIBIT I

2 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK FLAVIA ABREU, EFILED Plaintiff Index No.: /2014 -against- RESPONSE TO PLAINTIFF'S, d/b/a "AMIR CONVENIENCE DEMAND FOR LAST STORE", KNOWN ADDRESSES OF EMPLOYEE WITNESSES Defendants The defendant,, by and through its attorneys, MINTZER, SAROWITZ, ZERIS, LEDVA & MEYERS, LLP, as and for its Response to Plaintiff's Demand for last known addresses of defendant's former employees, states as follows: 1. SUNIL GURAGAIN and his last known address is 86-OS 35th Avenue, Jackson Heights, New Yorlc. 2. FARDUSH ALAM and his last known address is 216 Dahil Road, Apartment #2, Brooklyn, New York. PLEASE TAKE FURTHER NOTICE, that the answering defendant reserve the right to supplement the above responses should additional information become available. Dated: New York, New York March 10, 2016 Yours, etc. ~~ a. By: Leslie D. l~icmillan, Esq. MINTZER, SAROWITZ, ZERIS LEDVA & MEYERS, LLP Attorney for Defendant 39 Broadway, Suite 950 New York, NY (212) File #

3 TO: Steven A. Hoffner, Esq. LAW OFFICES OF STEVEN A. HOFFNER ESQ. Attorney for Plaintiff FLAVIA ABREU 325 Broadway, Suite 505 New York, New York 10007

4 STATE OF NEW YORK, COUNTY OF NEW YORK s.s.: AFFIDAVIT OF SERVICE BY MAIL FRANCES RIZZUTO, being duly sworn deposes and says that she is secretary to MINTZER SAROWITZ ZERIS LEDVA & MEYERS, LLP, the attorneys for the defendant and is not a party to this action. That on March 10, 2016, deponent served the within RESPONSE TO PLAINTIFF'S DEMAND FOR LAST KNOWN ADDRESSES OF EMPLOYEE WITNESSES upon: Steven A. Hoffner, Esq. LAW OFFICES OF STEVEN A. HOFFNER ESQ. Attorney for Plaintiff FLAVIA ABREU 325 Broadway, Suite 505 New Yorlc, NY the addresses designated by said attorneys for that purpose by depositing a true copy of same enclosed in a postpaid properly addressed wrapper in - a post office -official depository under the exclusive care and custody of the United States post office department within the State of New York. Deponent is over the age of eighteen. /~`~.'~. FRANCES RIZZUTO Sworn to before me March 10, 2016 otary Public Jacklyn E. Conner Notary Public State of New York No Qualified in Bronx County Commission Expires August 31, 2017

5 EFILED: INDEX NO /2014 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK FLAVIA ABREU, Plaintiffs) -against-, d/b/a "AMIR CONVENIENCE STORE"', Defendant(s). RESPONSE TO PLAINTIFF'S DEMAND FOR LAST KNOWN ADDRESSES OF EMPLOYEE WITNESSES MINTZER SAROWITZ ZERIS LEDVA & MEYERS, LLP Attorneys for Defendant. 39 Broadway -Suite 950 New York, New York (212) Our File: CERTIFICATION PURSUANT TO 22 N.Y.C.R.R. & a LESLIE D. MCMILLAN, ESQ. hereby certifies that, pursuant to 22 N.Y.C.R.R a, the foregoing RESPONSE TO PLAINTIFF'S DEMAND FOR LAST KNOWN ADDRESSES OF EMPLOYEE WITNESSES is not frivolous nor frivolously presented. r ~ v~ U lam" Dated: New York, New York E IE D. MCMILLAN, ESQ. March 10,2016 PLEASE TAKE NOTICE that the within is a true copy of a entered in the office of the clerk of the within named Court on that a of which the within is a true copy will be presented for settlement to the Hon. one of the judges of the within named Court at, on at 930 a.m. MINTZER SAROWITZ ZERIS LEDVA & MEYERS, LLP Attorneys for Defendant 39 Broadway -Suite 950 New York, New York (212)