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SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK

Index No. 061458/2013  

AMERICAN EXPRESS BANK, FSB                    APPENDIX 7

    -v-                                     ROSENBLUM INTENDED CALENDAR ITEMS IN THIS ACTION

DANIEL M ROSENBLUM

attorney of record Zwicker & Associates action commenced July 2013 Amex card 371339213796009

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SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK            

Index No. 100156/2011

AMERICAN EXPRESS BANK, FSB                   APPENDIX 7 

    -v-                                      ROSENBLUM INTENDED CALENDAR ITEMSIN THIS ACTION

DANIEL M ROSENBLUM

attorney of record Jaffe & Asher action commenced March 2011 Amex card 371339213796009

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THE FOLLOWING INFORMATION IN THE ABOVE CAPTIONED MATTER(S) IS HEREBY PRESENTED TO THE GENERAL PUBLIC AND NEW YORK STATE SUPREME COURT, SUFFOLK COUNTY & NY COUNTY....

      ....AS AN APPENDIX TO MY INFORMATIONAL SUPPLEMENT IN ANSWER TO THE ABOVE CAPTIONED MATTERS, SUBMITTED BY DEFENDANT DANIEL M ROSENBLUM ("I", "ROSENBLUM" and "DMR" below.)

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  1. 1. The foregoing is {DMR#9} Appendix 7 of 18, referred to first in the writing DMRAMEX09152013(Answer 2/Information Efile Document #8)  at ¶  10 et. al. and   also ¶s ¶ ¶ ¶¶ on the Subject Matter : "ROSENBLUM INTENDED CALENDAR IN THIS ACTION", Efiled Document #15.
  3. Rosenblum is a staunch adcovate of the importance of the banking industry in capital economy. Rosenblum is a staunch advocate of the power of banking as a driving force for production, innovation, and efficiency in a capital economy. Rosenblum is a stauch advocate of entreprenuerial endeavor, entrepreneurial endeavor and innovation go hand in hand in a capital marketplace; and Rosenblum is Sole Proprietor of 21st Century Digital, which Rosenblum establised on December 9, 1996, by filing a DBA with the NY County Clerk's at 60 Centre Street NY NY. Please see concluding paragraph ¶ 33 in the main document DMR091513 Efiled September 15 2013, for a link and Efile reference to the final Appendix #18 of 18, "Business Certificates: Daniel M. Rosenblum Sole Proprietor of  21st Century Digital, TTS Industries, and TMTP USA Unlimited."  Appendix 18 of 18, Efiled Document #27.
  5. Calendar of intended actions by rosenblum: {add dates and additional items}.
  7. Notification to Sanford Asher and Paul Zwicker, other partners/corporate officers.
  9. Notification to General Counsel office at American Express.
  11. Note that today 9/15/2013 I have Efiled in the Suffolk Case, which filings can be reviewed by accessing the NY State Supreme Court  Efile system and finding the case by the Index Number. As indicated in my "Calendar" Appendix, it is my intention to file an RJI in Suffolk in the case hopefully by Thanksgiving  2013 at the latest. It is also my opinion that given the record in NY and Suffolk, both cases must eventually be properly terminated by Order or Stipulation, even following American Express is paid in full, in accordance with my appendix filed in Suffolk discussing a "just result".
  13. The foregoing are intended calendar. I should note that for me, DMR, the dates are more subject to change than is the subject matter as intended calendar. Given Resources, and agenda, and status quo, the dates may switch dramatically- something calnedared for 3rd quRTER 2013MAY occur 4th qurter 2014 whereas a 2nd quarter 2014 item may be facilitated 4th quarter 2013 because of some situation which may arise/present- for example, the 2nd Amex Suit was unanticipated, but, during July and August and Septemebr I devoted resources towards the current filing which otherwise was not in anticipation for 9/15/2013= nor a surprise to the parties. For now, I look to aim for the below dates but am also otherwise quite busy and cannot spend 24/7 at my desk or in a truck as was the case July August and September:
  15. Letter to office of court administration regarding CPLR and cashier at Centre Street.
  16. Labor Day 2013 :   Filing of information in Suffolk County.
  18. Request for judicial intervention in Suffolk County. (This is partially dependent upon ability of Rosenblum to have funds available to pay the fee for an RJI)
  20. Hopefully way before Thanksgiving of 2013 the New York County Index # 100156/2011 will be converted to EFile, which requires only the consent of presumably American Express Bank FSB and/or their attorney Jaffe and Asher. Here is an image of the form I have completed thus far to convert the case:
  23. RJI in Suffolk County.
  25. Have Zwicker preserve all telephone records associated with collection activity.
  27. Examination of Jaffe Eric Calantone notary on notice of discontinuance and multiple RJI by swearing there were no previous RJ I.
  29. include note on attachment in E-file cases, e file cases instructing defendant answer electronically only because paper will be rejected. Write an affidavit swearing no such attachment in Zwicker summons and complaint.
  31. Rosenblum notes of mind presently to suggest that prior to Labor Day 2013, $1 milllion would have sufficed to stipulate on one action in either Suffolk or New York, to properly end the action alone and pay amex in full but with no other conditions or releases. Note that Rosenblum in the end desires a "Just Result" as articulated variosly, and, that, in a "Just Result" scenario the abuses alleged by the firms would be corrected; The preseumption by Rosenblum is that in one scenario Rosenblum would Stipulate to Discontinue under the impression that the firms will on their own accord correct such abuses rather than with commensurate adversarial litigation towards such correction. However, in such scenario, Rosenblum would reserve the right to pursue such corrections through litigation after a certain time period, for example, 18 months of March 2015. Following Labor Day, through Columbus Day 2013, without making further calculations, for ease of reference, following Labor Day filing and all related costs etc, at present the projected figure is $ 1.25 million given additional projected revenues and costs associated with litigation. Columbus Day projected as 1.5 Thanksgiving to Christmas projected as 1.75, presumably in relation to any chart that Amex would have for earnings etc commensurate with 2006 36,000 Platinum line. Certainly Rosenblum is open to review Amex projections for earnings as a guideline and amend these figures. Note again allocation of incoming resources necessary to home ownership, automobile, payments towards educational debt, etc as part of disposable income commensurate to projected earnings during time period 2006-2013 JD MBA etc. If New Years passes, at January 1 2014 presumably a new projected figure, as with March 23 2014 and at July 4 2014.These figures are projected as for the termination of the Amex Claim (Amex would be paid full debt incurred by Rosenblum if Rosenblum came into equivalent dollar amount) and first action in either Suffolk or New York. Much editing may be necessary here, and, this document therefore remains currently an informal information towards efficient, just, productive results all things considered.
  33. addition: DMR notes that the full 9/15/2013 filing is part and parcel of an outline for additional, future filings if necessary in this or related judicial proceedings; therefore the full filing and documentation has been formatted for publication on both the web and in court- and to be used in amended format but that resources and the calendar
    34. necessitate present filing in Suffolk of the instant filing and rough draft of intended calendar as per above, even unfinished and with "rough edges" in the filing.
  34. addition:addition:
  35. addition:addition: