Mr. Paduano sent the above insurance application with false information about 286 LLC. 

• Mr. Paduano claims 286 LLC is in business for "1 year." it was not even registered until May 13, 2014.

• Mr. Paduano lies that 286 LLC has a liquor license.

• Mr. Paduano claims he is a passive investor. His law firm office manager was his appointed 'controller' of W&R LLC. 

• Mr. Paduano claims i own 100% on every business and government record Mr. Paduano ever created. 

• Mr. Paduano, as usual, blamed the insurance company agent for negligence, when it was, he, himself, that was ignorant enough to not have obtained insurance on May 5, 2014. 

• In fact, he did not know how to get proper restaurant insurance obtaining quotes for over $90,000.00 a year. 

• After an entire month of ignorance, he finally came to me for help as a last-ditch effort to obtain a proper insurance quote.

• I obtained the insurance in an hour for only $13,000 a month. I was supposed to be the sole manager of operations. And yet they kept me out of the loop on matters as urgent and serious as this.

I AM THE ONLY 100% SIGNEE ON THE INSURANCE POLICY, THE LEASE, AND THE LIQUOR LICENSE, AND EVERY OTHER OFFICIAL DOCUMENT. ANY FRAUD COMMITTED BY MR. PADUANO BECOMES "MY" LIABILITY.

That is all he was pitching from day one - "curve balls."

Mr. Paduano panicked (rightfully so) in the middle of these insurance conversations and wrote us the above email. That was the end of the bar. 

He wanted out three weeks after he got in.

Mr. Paduano believed that the outrageously excessive insurance quotes that Mr. Walsh obtained for over $90,000 per year were legitimate normal priced quotes. 

****************

If Mr. Paduano did not have to lie to judge coin that he was signing the bar to only me as he was supposed to, and not himself and his new 286 LLC - he would have been able to file for a new corporation with no debts at all, just like any other normal businessperson would do.

Before the bar reopened, i had already emailed Mr. Paduano a photo of the expired insurance license hung on the bar's wall, writing him that it was expired and telling him it had to be renewed before the bar was assigned to us because we were immediately responsible for the space and the sidewalk in front. 

The dozens of emails below are examples of the extraordinary length Mr. Paduano would go to not take responsibility for his own mistakes. This was his modus operandi. Blame the victim. Blame anyone. Mr. Paduano knows he has only himself to blame.

It took them a month of gross negligence to finally inform me i had no insurance, i immediately secured an insurance quote for $13,558.23 in a few hours. 

They thought $90,000.00 quotes were normal for the industry. I obtained the insurance the same day they finally notified of their error.

++++++++++++++++++++++++++++++++

This caused Mr. Paduano's "curve ball" email that same night on May 30, 2014: he told us he wanted out, to sell the bar, or close it. He could not "stomach the liabilities anymore"...himself.

++++++++++++++++++++++++++++++++

I obtained a quote for $13,558.23 in one hour. Then Mr. Paduano sent an email asking me to bat them down,calling my quote "high.'' he had 3 people running in circles with his excuses, blame, and confusion. 

After saving them from themselves, Mr. Paduano then had the gall to blame me for 'my not knowing' they did not get insurance for over a month. On May 1, 2014, 

Mr. Paduano and Mr. Walsh know how to run a law firm, not a restaurant.

They had no idea of what to expect or what is normal in my business. If they did, they would not have replaced Charlotte with Mr. Paduano's office manager. 

After 4 years of handling my lawsuit, how could Mr. Paduano still be so ignorant to think that because he ran a small, straight forward, 'white collar' law firm billing for hours qualifies him and his office manager to instantly become the controller of a bar, in his spare time, off premise in the middle of his law office manager responsibilities.

From 1980 until 2003, Todd created a half dozen white collar companies in the telecommunications business. One of them had over a hundred employees with offices on both coasts. This company performed "customized billing services" for AT&T'S large corporate customers. Todd's headquarters were on the entire 10,000 sq. Ft. 15th (really the 9th) floor of trump tower on Fifth Avenue with over $50,000,000 in gross revenues. 

We knew the difference between a bartender and barrister. We found out the hard way. We invented the wine bar industry by creating the first one, we built it, operated it, ...and, single-handedly made it into a famous success.

But my lawyer thought he could run it better - after four years of suing meddling amateur narcissists like himself that were drunk with power.

MR. PADUANO TOOK OVER EVERYTHING - AND BLAMES ME FOR HIS IGNORANCE IN ORDER TO AVOID HIS OWN RESPONSIBILITIES.   I KNOW WHAT I AM DOING (from 10 years of experience BUILDING and then OPERATING "2" successful bars.  They would have stayed successful except for THE MEDDLING INVESTORS. 

More lies. Get access to what? They already had access to all the documents, or why would i be asking them for ones i did not have.

***Mr. Paduano warns us to be careful to not "misrepresent the ownership." i am not even sure 'whose ownership of what' he meant anymore. 

Because of Mr. Paduano's conflicts of interest and ensuing frauds, how can i 'not' misrepresent the ownership no matter who i say owns it? I'm damned any which way i represented the ownership...or anything else.

Mr. Paduano was now making me an unwilling accomplice to his insurance fraud. I felt like a hostage under Mr. Paduano's employment. 

***the insurance company would never honor any claim made i made as the 100% owner of W&R LLC, nor 286 LLC as the 49% owner, because it would have the same result: the company was already in violation of state liquor laws and other frauds. It should have been closed down. 

That fact would instantly come out during any insurance claim investigation. And then, according to Mr. Paduano's retroactive excuses he would just blame me and commit more frauds in my name to cover it up. 

Mr. Paduano's claim that there was "silence" on my part for a week, implying i had purposefully held back information, is lame. He and Mr. Walsh were in hourly contact with me and never mentioned it.

Mr. Paduano constantly insulted me by not copying me on emails to Todd. Four people cannot be 'the' manager of the bar. Operationally, it was like the three stooges meets Abott and Costello. 

Forget about the army of law office assistants and my limited time in a day. I was running two bars at the same time with competing hostile investors that thought they were in competition with each other... And me. 

MR. PADUANO INFORMS ME INSURANCE IS IMPORTANT!  HE WAS SUPPOSED TO GET IT NOW HE WAS BLAMING ME?

HE  IMPLIES I DON'T NEED TO UNDERSTAND ANYTHING, EXCEPT WHAT HE TELLS ME.

THAT IS THE CAUSE OF MY CONFUSION IN THE FIRST PLACE.

HE WAS MY LAWYER AND ALLEGED PARTNER, WHY DID THEY NOT TAKE CARE OF THE INSURANCE ON THE VERY FIRST DAY, LIKE EVERY OTHER NORMAL RETAIL ESTABLISHMENT?

WHY WAS I FIRST FINDING OUT ABOUT THIS MATTER ON MAY 30, 2014?  

More lies. Mr. Walsh 'discovered' (???) That the insurance policy lapsed? He received a notice that it lapsed, about the 2nd week in May. Then he and Mr. Paduano negligently tried to do it themselves. 

Why was i first being informed on May 30, 2014?

It is clear Mr. Paduano never takes responsibility for anything and blames me for his own inexperience and ignorance.

They were working on it for weeks (or should have been) without me. Getting completely wrong numbers. Some of them in excess of a $90,000 per year. Around $8,000 per month. That would kill the business in and of itself. 

According to another email 'dated May 30, 2014' Mr. Paduano said Mr. Walsh had 'discovered' this 'lapse' approximately 2 weeks ago, which would be May 15, 2014. Discovered? He was mailed a discontinuance notice from the insurance company!

Why did they not tell me then about the confusion they were reeking that was the cause of the lapse in the first place? - because they were out to show me how much smarter they were? 

The insurance company is the first company to call the day you take possession of a retail location. They should have contacted and arranged insurance to begin on May 5, 2014, in case somebody fell on the sidewalk on May 6, 2014. 

"Please put tom in charge" why? Mr. Walsh was already in charge! 

"CAESAR GETS PAID IN 30 DAYS."

Mr. Paduano begins harassing us to start paying him back our $400,000.00 debt beginning July? 

This is where Mr. Walsh informed Mr. Paduano of how the $25,000.00 that ruth gave from their joint account. He accused me of "vaporizing" it in another email. He was accusing me of malfeasance before we even opened the bar. Great partner.

We only had the $45,000 to completely renovate the bar soup to nuts and restock it with a wine cellar that was supposed to have good wine. 

The other $80,000.00 in the settlement went to pay the former investors. 

Mr. Paduano proclaimed, "you won, Jennifer, you won." 

Mr. Paduano probably sent over a dozen emails saying that we had to put Mr. Walsh in charge. I never said no. I merrily thought he was going to be a bookkeeper. Then suddenly he was the controller who Mr. Paduano wrote:

• "would control the company as he sees fit." and,

• "his idea of running a (restaurant)" as Mr. Paduano insisted, "would be far different than mine." "and 

• "there would be nothing i could do about it." 

I could not even leave according to his secret 286 LLC agreement. He would sue me.

Maybe Mr. Paduano thought by 'belatedly' telling us this, it absolved him for doing it? We just said, "yes sir." as always. He was our boss. 

WHEN MR. WALSH COULD ONLY GIVE MR. PADUANO ABSURDLY OUTLANDISH INSURANCE QUOTES, MR. PADUANO WENT FROM HAVING COLD FEET TO HAVING FROST BITE.    

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DISCLAIMER:  I am not a lawyer.  My opinions and descriptions of the emails and documents displayed on this website, and my chosen nomenclatures for them, are strictly derived from my own layperson's understanding of the definitions of the applicable statutes and torts in basic legal reference manuals and guides.  All references to "crime" are alleged and used in accordance with its colloquial definition:  A grave offense, especially against morality.  Reprehensible, foolish, or disgraceful.  Evil, shameful, or wrong.