I
do note that this Year 2015 Yelp complaint seems to have never received any
on-line response to date from MAAVS or from Mister Wright, other than perhaps subsequent
attempts to dilute the Yelp review of “Dee D.” with other more positive posts
which followed it.
In
any event, I am serving this FOIL request on NYCDCWP seeking: (A) all Records
reflecting complaints or other communications from “Dee D.” of New Orleans, Louisiana
circa 2015; and, in addition, (B) all Records reflecting any other
complaints or other communications regarding MAAVS or Mister Wright,
from any other person or entity – as more fully iterated hereinbelow. Included
in each of these requests are any Records of your predecessor entity, the New
York City Department of Consumer Affairs (“NYCDCA”), which I understand that NYCDCWP
still maintains.
I
am an attorney in New York, and a citizen and resident of the Town of
Orangetown and the County of Rockland. Under the New York State Freedom of
Information Law:
and,
as may be applicable, its state, federal, and other counterparts, including
without limitation New York Public Officers Law, Article 6, Sections 84-90 -
Title 5 of the United States Code, Section 552 - and 43 RCNY §1-08(a) (all collectively
herein referred to as “FOIL”), request is hereby made that each of you provide
to this, my law office, full and complete copies of each and every document and
other item of material dated, generated, or otherwise materializing from January
1, 1986 forward to the present day (collectively, “Records”) which may be
at all responsive to the following requests:
1.
Date. My current information indicates that Mister Wright and
MAAVS commenced operations no earlier than January 1, 1986. Accordingly, I
would first ask that your search-parameters be set for any Records dating from January
1, 1986 through current Year 2025 and today’s date therein.
2.
Michael Andrews Audio Visual Services, Inc. In summary, I am
seeking all Records relating to Michael Andrews Audio Visual Services, Inc. (MAAVS).
Yet
according to thusfar-located public records, please
be aware that MAAVS and its predecessor entities (collectively, the “MAAVS
Entities”) may also be known by the following aliases and alternate names:
“Michael Andrews AV Services, Inc.”
“Michael Andrews Audio Visual”
“maavs.com”
“Wright Images”
“AVCOM Motion Picture And Video Supply”
“Industrial Theatre, Inc.”
“Stage Right Associates, Inc.”
“Stage Light, Inc.”
“rentalandstaging.net”
“meyersound.com”
3.
Addresses. According to thusfar-located public records, the MAAVS
Entities may be associated with any or all of the following addresses:
625 West 55th Street, Floor 3
New York, New York 10019-3560 USA
653 11th Avenue
New York, New York 10036-2004 USA
[ ] Street
Piermont, New York 10968-2622 USA
136 Waters Edge
Congers, New York 10922-2622 USA
134 Myer Street
Hackensack, New Jersey 07601 USA
150 Louis Street
South Hackensack, New Jersey 07606 USA
[ ] Place
Glen Cove, New York 11542-3075 USA
[ ] Parsons Boulevard
Flushing, New York 11355-2334 USA
[ ] East 72nd Street [ ]
New York, New York 10021-4626 USA
4.
Names Of The MAAVS Principal. The principal of the MAAVS
Entities, Mister Wright, is known as:
Michael Emerson Wright
alias “Michael
E. Wright”
alias “Michael
Wright”
alias “Mike
Wright”
alias “Michael
Andrews”.
Mister
Wright currently serves as Trustee for the Hudson River Valley Village of
Piermont, New York.
To
my knowledge, Mister Wright does not use the “Michael Andrews” alias
when serving as Piermont Village Trustee, though.
5.
Incidents, Complaints, Claims, And Litigations.
Specifically, I am seeking all Records reflecting,
referencing, or otherwise relating to any incidents, complaints, claims,
mediations, arbitrations, or litigations, about, concerning, or otherwise
relating to the MAAVS Entities or Mister Wright, if any.
6.
Enforcement Actions. Specifically, I am seeking all Records reflecting,
referencing, or otherwise relating to any enforcement actions or comparable
actions against, about, concerning, or otherwise relating to the MAAVS Entities
or Mister Wright, if any.
7.
License Transfers. Specifically, I am seeking all Records reflecting,
referencing, or otherwise relating to any transfer of any license or other
transfers of value, of, by, for, or otherwise concerning the MAAVS Entities or
Mister Wright.
8.
E-Mails And Correspondence. Specifically, I am seeking all
Records of any e-mails, memos, notes, correspondence, documents, or other
writings to, from, referencing, or otherwise relating to the MAAVS Entities or
Mister Wright.
9.
Fines Or Other Penalties. Specifically, I am seeking all Records reflecting,
referencing, or otherwise relating to any fines or other penalties assessed
against or otherwise imposed upon the MAAVS Entities or Mister Wright, if any.
10.
Violations, If Any. Specifically, I am seeking all Records
reflecting, referencing, or otherwise relating to any violation or claimed
violation of any other laws, statutes, ordinances, regulations, rules,
requirements, or standards by, concerning, or otherwise relating to the MAAVS Entities
or Mister Wright, if any. I am seeking each and every Record reflecting any
“violation”, “reporting violation”, or other past, present, future, or
anticipated violation, breach, or other transgression of federal, state,
county, town, local, or other ordinance, rule, regulation, requirement, or
other law or standard - including without limitation any violation of rules,
regulations, or other laws enforced by or otherwise relating to or concerning
any of the following, to the extent evidence of same might be retained in
your own NYCDCWP Records:
United States Department Of Justice (USDOJ).
U.S. Attorney’s Office (USATTY).
Federal Bureau Of Investigation (FBI).
Office of the New York State Governor (NYS GOV).
New York State Attorney General’s Office (NYSAG).
New York State Department of Financial Services
(NYSDFS).
All other New York state and local agencies.
All other New Jersey state and local agencies.
Any other potentially-relevant government agency or
authority.
11.
All Other Records. Specifically, I am seeking all other Records
of any other kind or nature relating to the MAAVS Entities or Mister Wright.
12.
Definition Of “Records”. “Records” should be construed in the
broadest sense and manner possible and should include “any information kept,
held, filed, produced or reproduced by, with or for (your agency or office)...
in any physical form whatsoever...” (FOIL,§86[4]) including without limitation
all audio recordings, blog posts, correspondence, data maintained
electronically, data, e-mails, executive summaries, extracts, faxes, instant
messages, Internet posts, letters, log-book entries, memos, paper records,
personal messages, social media communications, spreadsheets, summaries,
synopses, telephone records, test-reports, visual recordings, and any other
materials:
13.
Headings And Subheadings. The headings and subheadings used in
this letter are for convenience of reference purposes only, and should not be
construed to be words of limitation or otherwise of any substantive
significance relative to this FOIL request.
14.
Costs. If there are any copying or other fees for this, please
let me know what they are and how they are calculated, before filling the
request and forwarding the Records to me. As this FOIL should be considered a
matter of public importance, and as its results will be shared with the general
public and published, I am asking that any otherwise-applicable fees be waived
for this document-production. I am also asking that all documents be provided
to me electronically to the full extent possible, so as to obviate the need for
any photocopying expense.
15.
Denials And Appeals. In the event that any portion of my request
is denied, please inform me of each of the specific reasons for any such denial
in writing - and provide me with the name, address, and other contact
information of the person or entity to whom an appeal should be directed.
16.
Additional Requests. This FOIL request is not intended to be
exhaustive, and I may make additional and follow-up requests.
I
will appreciate a response from you and your office as soon as possible. I look
forward to hearing from you. Thank you.
Respectfully,
and with thanks,
John
J. Tormey III, Esq.
cc:
VIA
FAX: 1-518-474-1927, U.S. MAIL, and E-MAIL:
NYS
Committee on Open Government (COOG)
Department
of State
One
Commerce Plaza, 99 Washington Avenue, Suite 650
Albany,
New York 12231 USA
