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Pryor Cashman Correspondence — Counsel Review and Filing Plan (September 11 & 16, 2026)

Version: v1.0 | Updated: 2026-09-16

This page archives, verbatim, the two emails received from Matthew A. Marcucci of Pryor Cashman LLP following the firm's review of the September 4, 2026 five-email transmission in Christian Gray v. American Package Co., Inc. (HP 6086/2020; Index No. 506171/2021). Both arrived on the Transmittal 5 thread. The first, September 11, confirms counsel's review of the full set; the second, September 16, states the firm's litigation plan: two filings, tentatively early to mid-October 2026. The transmittal index carries the set these emails respond to.

Thread Sequence

# Date / Time (EDT) From Content Record
1 Sep 4, 2026, 5:25:54 PM Christian Gray Transmittal 5 — Sandercock July 2022 figures, five questions Sent-message MD5 b2e57164
2 Sep 11, 2026, 12:38:14 PM Matt Marcucci Review confirmation — "useful stuff... especially... the release signing" Received-message MD5 2437bc35 (Email 1 below)
3 Sep 11, 2026, 12:42 PM Christian Gray Brief acknowledgment Preserved in the quoted thread of the September 16 message
4 Sep 16, 2026, 3:46:11 PM Matt Marcucci Filing plan — two vehicles, early/mid-October Received-message MD5 a33f879f (Email 2 below)

Email 1 — Review Confirmation (September 11, 2026)

Receipt Metadata

Field Value
Date September 11, 2026, 12:38:14 PM EDT (header 16:38:14 UTC, explicit offset)
From Matthew A. Marcucci, Pryor Cashman LLP
To Christian Gray (Proton Mail)
Cc Eric Sherman, Pryor Cashman LLP
Subject RE: Sandercock July 31, 2022 email re: the damages figures in the original complaint — five questions
Thread Reply to Transmittal 5 (September 4, 2026, 5:25:54 PM)
As-received source Proton Mail export of the received message, MD5 2437bc35
Attachments None

As-Received Body

Christian: Just dropping you a note to let you know that I've read through all of these materials. I think there will be some useful stuff in here for us as we move forward—especially with respect to your back-and-forth with Sandercock on the release signing. We'll be in touch sometime next week. Thanks. –Matt

Email 2 — Filing Plan (September 16, 2026)

Receipt Metadata

Field Value
Date September 16, 2026, 3:46:11 PM EDT (header 19:46:11 UTC, explicit offset)
From Matthew A. Marcucci, Pryor Cashman LLP
To Christian Gray (Proton Mail)
Cc Eric Sherman, Pryor Cashman LLP
Subject RE: Sandercock July 31, 2022 email re: the damages figures in the original complaint — five questions
Thread Reply to Christian Gray's September 11, 2026, 12:42 PM acknowledgment on the Transmittal 5 thread
As-received source Proton Mail export of the received message, MD5 a33f879f
Attachments None

As-Received Body

Christian: To give you a sense of timing and precise next steps, and as we have generally discussed, we are going to draft the following papers for your review, with a tentative plan of filing sometime in early or mid-October: (1) an amended complaint, together with papers in support of a motion for leave to amend (a procedural requirement), in the pending Supreme Court action filed by Sandercock, which will expand on the claims already pled there; and (2) a separate complaint arising from the breach of repair obligations under the June 2021 settlement stipulation and attendant fraud, to be filed as a new, standalone action. (This is a very high-level and simplified overview, of course.) We will send these papers to you for review when ready. If we have any questions during the drafting process, I will reach out. Please feel free to do the same. Thank you. –Matt

What the September 16 Email States

As stated by counsel, the firm will draft, for client review before filing:

  1. An amended complaint, with papers supporting a motion for leave to amend, in the pending Supreme Court action filed by Sandercock (Index No. 506171/2021), expanding on the claims already pled there.
  2. A separate complaint arising from the breach of repair obligations under the June 2021 settlement stipulation and the attendant fraud, filed as a new, standalone action.

Tentative filing window: early to mid-October 2026. Counsel characterized this as a high-level and simplified overview.

END — Pryor Cashman Correspondence — Counsel Review and Filing Plan (September 11 & 16, 2026) v1.0