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Pryor Cashman Q11 Addendum — WT-120A / Nov. 3, 2022 Skaller Proposal

Version: v1.5 | Updated: 2026-04-03

Post-Submission Addendum

This addendum sits alongside the submitted Q11 response and does not replace it. It preserves a later-discovered November 3, 2022 record (WT-120A) that post-dates the core Q11 pre-stipulation analysis but is relevant as a late-stage corroborating artifact.

Why This Addendum Exists

Q11 is principally a pre-stipulation question. WT-120A is not a pre-stipulation document. It is a late-stage November 3, 2022 record that post-dates the stipulation, the post-remediation dispute, the Motion to Restore, the opposition affidavits, and the October 2022 pressure period.

For that reason, WT-120A does not belong as a major pillar in the core Q11 answer. But it is still relevant enough to preserve in the Pryor Cashman lane because it strengthens the later record in three narrow ways:

  1. It confirms that the stipulation / remediation dispute was still unresolved in November 2022.
  2. It documents that a new stipulation architecture was being proposed to replace the broken or disputed prior path.
  3. It shows that withdrawal of the Jack Glass / Candice Kowalewski affidavits was expressly part of the contemplated cure structure.

That makes WT-120A a useful late-stage corroborating record for the broader Sandercock / Skaller / settlement-architecture sequence, even though it does not change the main pre-stipulation analysis in Q11.

Source Artifacts

White page: WT-120A — Skaller Proposed New Stipulation

Source PDF: WT-120A Source — Skaller Nov. 3, 2022 Email (PDF)

Probable attached remaining-scope match (not confirmed): WT-110A — ALC Additional Scope of Work, Nov. 2022 (PDF) | White page: WT-110A

Provenance / Archive Location

WT-120A is not an unattributed orphan document.

The source PDF itself shows a November 3, 2022, 11:29 AM email from David Skaller to Margaret Sandercock, subject "FW: Attached Image." The same record also appears in the Sandercock correspondence archive as a later same-day forward from Sandercock to Christian Gray, cc: Adam Goodfarb, with Sandercock stating: "The above proposed agreement and email below concern your HP case. I have already, separately, sent these things to Ed Olmsted."

That means the current record supports the following provenance sequence:

  • Skaller sent the proposal to Sandercock on November 3, 2022.
  • Sandercock forwarded it to Gray later that day.
  • Sandercock represented that she had already separately sent the materials to Ed Olmsted.

This is important because it clarifies that WT-120A was already an active Sandercock-side circulated document during the final week of her representation. It was not merely a later stray attachment that surfaced only through successor counsel.

The Kozek archive separately shows that on November 7, 2022, Sandercock sent Nina Oksman and Michael Kozek a scope-related email titled "FW: scope of work 97 Green - Christian Gray." That confirms that G21 scope materials were being transmitted during the Sandercock-to-Kozek transition. But on the current record, that November 7 transfer does not by itself prove that the exact WT-120A Skaller proposal was the same attachment in that later Kozek email. It supports possible successor-file inheritance, but not exclusive provenance.

What WT-120A Shows

WT-120A is based on a one-page November 3, 2022 email from David Skaller to Margaret Sandercock, marked "FOR SETTLEMENT PURPOSES ONLY."

The document reflects a proposed new stipulation of settlement and states, in substance, that:

  • Jack had prepared a new scope of work.
  • Ed had indicated at the last apartment meeting that the new scope was acceptable as the remaining scope of work.
  • Access would be given to ServPro and two other contractors to bid that work.
  • Both Jack and Ed would be present so the bidders understood and agreed to perform the scope.
  • Once a remediation contractor was selected, access would be given to perform that work.
  • Jack and Ed would both be present on the last day of remediation so additional work could be done immediately if both experts agreed.
  • Both experts could test that day or within one week of completion.
  • If the experts disagreed about additional work, a pre-selected third party would determine whether the work was within the stipulated scope and who would pay.
  • Upon full execution of the new stipulation, the parties would agree to withdraw the affidavits of Jack and Candice.
  • After completion of the work, Gray would provide access to the respondent's contractors to perform legalization work pursuant to approved DOB / Loft Board plans.

Clarification on the Roussis / Stipulation Relationship

This addendum should be read together with the later scope-comparison work in WT-120.

The original Q11 response was written from the standpoint of sustained pre-signing friction over remediation completeness and repeated pressure to stop demanding disputed items. That remains accurate. But the later comparison work in WT-120 sharpens the formulation: on paper, Stipulation Exhibit 1 largely preserved the broad invasive remediation architecture reflected in the earlier Roussis / Total Restoration scope. The later White analysis shows that the stronger factual point is not simply that the stipulation was categorically stripped down from the beginning. The stronger point is that the record reflects pressure to stop demanding disputed items, embedded narrowing comments inside the filed scope exhibit, and an "accept less now / fight later" posture that later matured into execution and compliance failure.

WT-120A matters in that refined framework because it shows that, by November 3, 2022, the matter still had to be addressed through a proposed new stipulation with a revised remaining scope, expert-supervised completion mechanics, and neutral dispute-resolution structure. In that sense, WT-120A is not a contradiction of the pre-signing friction record; it is a later corroborating sign that the scope problem had never been cleanly resolved.

Limited Relevance to Q11

What It Does Support

WT-120A supports a limited later-stage proposition:

By November 2022, the existing stipulation / compliance path had not produced a stable or trusted resolution, and a replacement settlement structure was being proposed that tied revised scope oversight to expert participation, neutral dispute resolution, and withdrawal of the Jack / Candice affidavits.

That is relevant to the broader Sandercock / Skaller history and is worth preserving for Pryor Cashman as a later corroborating record.

What It Does Not Do

WT-120A does not do the following:

  • It does not change the core pre-stipulation focus of Q11.
  • It does not prove, by itself, that the Jack / Candice affidavits were false.
  • It does not contain the phrase "not accurate."
  • It does not establish, by itself, why Sandercock or Kozek did or did not act on the proposal.
  • It does not supply the attached revised scope package itself; that separate attachment has not yet been independently located with definitive attachment metadata in the present corpus.

For those reasons, WT-120A should be treated as a supplemental late-stage corroborating record, not as a replacement theory anchor for Q11.

Why This Matters for the Pryor Cashman Record

This addendum may be useful to Pryor Cashman for three reasons.

1. It shows the dispute remained live after the original stipulation path failed.

The November 3, 2022 proposal confirms that the parties were still attempting to resolve the remediation / scope dispute through a revised formal structure long after the original stipulation and PRV process.

2. It ties the scope problem and affidavit problem together in one document.

WT-120A does not merely discuss additional work. It links: - a revised remaining scope, - expert-supervised contractor bidding and completion, - a neutral third-party decision-maker if the experts disagreed, and - withdrawal of the Jack / Candice affidavits upon execution.

That makes it a more consequential document than a simple "scope additions" email.

3. It creates clean follow-up questions for the successor-counsel / transition record.

The provenance record now answers several threshold questions. The remaining work is narrower:

  • Whether Sandercock responded substantively to Skaller or communicated further with Olmsted about the proposal beyond confirming that she had sent it along.
  • Whether Kozek received this exact proposal during transition, or only related scope materials.
  • Whether WT-110A is the same document as the "new scope of work that Jack prepared" referenced in Skaller's email. WT-110A is a probable match -- same authoring side, same month, same one-page format, and content consistent with "remaining scope" -- but the current record does not include attachment metadata that would confirm identity with certainty.

Timing Significance: Nov. 3 / Nov. 4 / Substitution Window

The timing of WT-120A gives the document added value.

The Skaller proposal is dated November 3, 2022. The tenant termination email followed on November 4, 2022. Substitution to Ween & Kozek occurred later in November 2022. That places WT-120A directly inside the transition window at the edge of Sandercock's exit from the matter.

Its significance is not that it changes the core pre-stipulation answer. Its significance is that it shows a documented late-stage attempt to replace the failed stipulation / compliance architecture with a new one immediately before Sandercock's role ended and successor counsel entered. That makes the document especially important for file-transition review and for any later assessment of what corrective options were preserved, acted on, or lost during the transition.

Open Questions / Use Limitations

Resolved

The following questions have been answered by the current documentary record:

  1. Was the proposal sent by Skaller to Sandercock? Yes. The source PDF itself shows a November 3, 2022, 11:29 AM email from David Skaller to Margaret Sandercock.
  2. Was the proposal forwarded by Sandercock to Gray? Yes. The Sandercock correspondence archive contains a later same-day forward from Sandercock to Gray.
  3. Did Sandercock say she separately sent it to Olmsted? Yes. In the same forward, Sandercock wrote that she had already, separately, sent "these things" to Ed Olmsted.
  4. Is WT-110A a plausible candidate for the attached remaining scope? Yes. WT-110A is a probable match for the "new scope of work that Jack prepared" referenced in Skaller's email. It remains a probable rather than confirmed match because attachment metadata has not yet been located.

Still Unresolved

  1. Whether Sandercock responded substantively to Skaller or communicated further with Olmsted about the proposal beyond confirming that she had sent it along.
  2. Whether Kozek received this exact proposal during file transition, or instead received only related scope materials. The November 7, 2022 Sandercock-to-Kozek transfer email ("FW: scope of work 97 Green - Christian Gray") confirms related scope transfer but does not prove exact attachment identity.
  3. Whether any draft new stipulation corresponding to the proposal was ever prepared.
  4. Whether WT-110A is definitively the same document as the Skaller attachment, or a related but distinct version of the remaining scope.

Summary

WT-120A is a narrowly useful late-stage corroborating record with a clear provenance chain. The proposal came from Skaller to Sandercock on November 3, 2022. Sandercock forwarded it to Gray later that same day and stated that she had separately sent the materials to Olmsted. The later Kozek archive shows related scope-transfer activity during transition, but does not by itself prove that the exact WT-120A proposal was the same attachment in the November 7, 2022 transfer email.

The "new scope of work that Jack prepared," referenced as attached to the Skaller email, is probably the document now in the corpus as WT-110A (ALC "Additional Scope of Work," November 2022). The match is strong on timing, format, and substance, though attachment metadata confirming exact identity has not yet been located.

WT-120A does not alter the core pre-stipulation analysis in Q11, and it does not by itself establish that the Jack / Candice affidavits were false.

END -- Pryor Cashman Q11 Addendum -- WT-120A / Nov. 3, 2022 Skaller Proposal v1.5