May 23, 2019

VIA ELECTRONIC MAIL

VIA U.S. MAIL

Spencer Sheehan
Sheehan & Associate. P.C.
spencer@spencersheehan.com

Michael R. Reese
Reese LLP
mreese@reesellp.com

Joshua Levin-Epstein
Levin-Epstein & Associates, P.C.
joshua@levinepstein.com

Re: Ricardo Sibrian v. Cento Fine Foods, et al., E.D.N.Y. No. 2:19-cv-00974-JS-GRB

Dear Counsel:

As you know, this firm represents Defendant Cento Fine Foods, Inc. (“Cento”) in the above
captioned matter. My client has informed me that service in this case was perfected on them on
Wednesday, May 15, 2019. Pursuant to Fed. R. Civ. P. 11(c)(2), this letter and the accompanying
draft Motion constitutes notice that Cento will file its Motion for Sanctions against your client and
your firms, jointly, following the anticipated dismissal of your baseless Complaint. As fully outlined
in our draft Motion, we find it likely that the Court will agree with our position that this suit was
frivolous when filed, and if maintained despite direct evidence vitiating your claims, frivolous at the
time of dismissal. The evidence we have supplied in support of our position – all subject to judicial
notice as it was referenced in your Complaint – cannot be refuted. Continuing to pursue unsupported
claims is objectively unreasonable. I invite you to use the 21 day “safe harbor” window to reevaluate
your backing of these unsupported claims and filing of this lawsuit. They are demonstratively false.

If forced to defend itself in Court, Cento has instructed me to pursue all of our legal fees,
translation costs and other expenses required for unnecessarily having to defend its good will. My
client has also instructed me to explore business disparagement claims if media attention to this
baseless suit negatively affect its sales or reputation in industry. I would welcome a call to discuss
this matter if you think a discussion would be helpful to understand the basis of our anticipated
motion.
 As you may notice from today’s ECF filings, my colleague, Erin Conway, has filed her
appearance in the case. My pro hac vice application will be forthcoming. I am the lead attorney on
the case so please direct all further communication to me.

Sincerely,

_/s/ Daniel S. Tyler______________________

Daniel S. Tyler (Pro Hac Vice forthcoming)
AMIN TALATI UPADHYE, LLP
100 S. Wacker Drive, Suite 2000
Chicago, IL 60606
T: (312) 784-1061
daniel@amintalati.com

Attorney for Defendant, Cento Fine Foods, Inc.

enclosures