How It Happened:

View Formal Demand Letter

Authored by: Albert Durante, Esq. Durante Bock and Tota PLLC, on behalf of Erika M. Widmann

Dated: January 5, 2021

Addressed to: Charlene Pateman

This letter, sent via U.S. Mail and email, announced Erika Widmann’s intent to dissolve an alleged partnership C & E Enterprises and demanded repayment of $25,000 ($20,000 investment plus $5,000 additional contribution) under a claimed right in Article 70 of the purported partnership agreement. It further ordered me to cease all product sales through Aegle4Wellness.com, asserting those sales involved partnership property, and to furnish an inventory of all products and sales by January 26, 2021. The letter also declared that the partnership had “terminated at the end of Phase I on July 31, 2020,” even though no such partnership or termination was mutually agreed upon or declared.

This letter marked the start of the legal conflict and introduced several misrepresentations that shaped the entire case: it misquoted Article 70, treated Aegle4Wellness, a business created independently after any association of had ended both personally and professionally. It was addressed solely to Charlene Pateman.

View Immediate Response, requests unattached purported agreement

This exchange establishes that the demand was promptly received and responsibly referred to counsel within minutes, proving that I acted in good faith and did not disregard the letter as later alleged.

View Summons and Verified Complaint

Authored by:Albert J. Durante, Esq., Durante Bock & Tota PLLC
Filed by:Durante Bock & Tota PLLC, Attorneys for Plaintiff Erika M. Widmann
Plaintiff:Erika M. Widmann
Defendant:Charlene A. Pateman a/k/a Charlene A. Schroeder
Court:Supreme Court of the State of New York, County of Putnam
Index No.: 500321/2021
Date Filed:February 16, 2021
Date Received (Certified Mail):February 17, 2021
Service Method:Certified mail, return receipt requested (as evidenced by certified envelope and receipt).;

The demand letter was also transmitted by email from Tammy Hopper at 4:21 PM, with both Albert Durante, Esq. and Melissa D’Ippolito, Esq. copied on the message.

Despite the attorneys’ receipt of the correspondence and Charlene’s immediate response, no acknowledgment or follow-up was made by D’Ippolito or Durante, and the firm later claimed that the letter had been “ignored.”

This record clearly establishes that the demand letter was acknowledged within minutes, but the sender’s own attorneys failed to act on the response, creating the false appearance of noncommunication.

This document marks the official start of litigation.
It restates the same narrative from the January 5, 2021 Demand Letter, alleging that a “Partnership Agreement” existed between the parties, that the partnership terminated on July 31, 2020, and that Article 70 entitled the plaintiff to reimbursement of $25,000.

No copy of the referenced agreement was attached or filed, despite my same-day written request for it on January 5, 2021. The filing instead asserts that the defendant “ignored” the demand letter and “failed to comply,” even though contemporaneous emails prove the opposite.

Misrepresentations and Procedural Issues

Falsely Portrayed Non-Response:
The complaint explicitly claims the defendant ignored the January 5 demand letter. In reality, I responded directly to the law firm within minutes, requesting a copy of the referenced agreement. This misrepresentation painted me as uncooperative and prejudiced the court’s early perception of the case.

Unverified Contract Basis:
The complaint relied on a document that had not been produced, verified, or provided to the defendant, leaving her unable to review or confirm what was being claimed as “Article 70.”

Improper or Misleading Identifiers:
The caption introduces “a/k/a Charlene A. Schroeder,” an alias never used in any prior correspondence. While “Schroeder” was my married name, it had never been used in any prior communication or document related to this matter. Its inclusion served no practical purpose and unnecessarily complicated the record, contributing to confusion about the defendant’s identity.

Unsubstantiated Financial Assertions:
The complaint repeats the same $25,000 figure but inconsistently describes the alleged contributions, referencing both $20,000 and $25,000 without supporting documentation.

SIGNIFICANCE

This filing set the tone for the case by embedding false premises as fact.

By stating that I ignored the demand letter, when the record shows immediate acknowledgment and inquiry, the complaint prejudiced my standing before the court from the outset. The action moved forward on a claim referencing a contractual clause never provided or authenticated, establishing a procedural imbalance that persisted throughout the litigation.

Click to view transcript > Erika Widmann Presents

September 3,

2024-Trial Hearing, Day One

By the time this trial finally began, I had already spent nearly four years trying to defend myself against a claim that should have been resolved by simply comparing the allegations with the agreement, the payment records, the emails and Erika Widmann’s own sworn statements.

On Day One, ErikamWidmann presents her case and claims that she invested $20,000 and became,entitled to $25,000 when she “opted out” under the alleged agreement.

However, that was not the only explanation given for why I supposedly owed her money. Her complaint alleged that the partnership automatically terminated on July 31. Elsewhere, she claimed she personally terminated it on July 29. The money was variously described as an investment, a reimbursement, money allegedly returned by a vendor, and reimbursement connected to returned products.

The testimony also exposed conflicting accounts concerning the vendor. Widmann’s verified filing blamed me exclusively for terminating that relationship and claimed that she still did not know why it ended. Yet her own emails accused the vendor of backing out, stopping the business and shutting it down with three days’ notice. The emails ultimately show that Widmann is the one that aggressively terminated the relationship.

In another email, Widmann expressly stated that The Farmer’s Touch and A Farmer’s Touch at Home were two separate corporations and that the dealings between me and her had nothing to do with Erika. But during an appearance in October 2022, she stated that my money I got back from the vendor for the business that had nothing to do with her, was our money and it was supposed to go into our joint account.

Rather than narrowing the case to these central inconsistencies, the hearing continued through years of accumulated allegations, unrelated expenses and unnecessary confusion. As a self-represented defendant who had already lost so much due to the destruction caused by the plaintiff, I was left trying to expose each contradiction while also navigating the rules of evidence and courtroom procedure.

This transcript is important because it allows the you to hear Widmann’s case in her own words and compare it directly with her emails, sworn filings, payment evidence and the agreement itself. It also illustrates my larger experience with the court system…a relatively straightforward dispute was permitted to become increasingly confused, prolonged and expensive while the most basic contradictions remained unresolved.

View Transcript > Charlene Pateman presents

September 5, 2024 — Trial Hearing, Day Two: My Defense

By the time I was finally permitted to present my defense, this case had consumed almost 4 years, approximately 40 court appearances, enormous amounts of paperwork and countless hours away from my business. I had already identified major inconsistencies in Widmann’s sworn filings, testimony, emails and alleged proof of payment.

Before beginning my case, I asked the court to dismiss the complaint because I believed Widmann had failed to prove the most basic elements of her claim… a valid agreement, her own complete performance, my alleged breach and legally supported damages.

The judge denied my application and allowed the case to continue.

I then attempted to bring the case back to its simplest question… If Widmann’s own complaint alleged that she paid the full second $10,000 installment within 30 days, where was the proof?

Widmann acknowledged that the second payment was not another $10,000 payment. She paid $7,000 and attempted to make up the missing $3,000 with changing combinations of alleged cash, credit-card purchases, product sales and business expenses. She testified that everything was completed by March 3, yet the invoices offered as proof included dates of March 6, March 14, April 10 through April 24 and even May. When her timeline became difficult to follow, the judge himself stated:

“That’s making even less sense than before.”

Her Verified Bill of Particulars said the remaining $3,000 was satisfied through “cash/credit card payments.” Her testimony added product sales and Amazon purchases. Her verified reply also admitted the allegation that she did not have the full $10,000 and paid only $7,000-although at trial she attempted to qualify that admission by saying, “Not in cash.”

This mattered because my position had remained consistent for years: there could be no breach based upon my supposed failure to return a fully paid $20,000 investment if Widmann never made the required payment in the manner and time alleged in her own complaint. Nevertheless, instead of resolving that threshold issue, the case continued expanding into unrelated expenses, credit-card receipts, products, Bethann Bruno and shifting explanations of what the money supposedly represented.

I also confronted Widmann with her conflicting accounts of the vendor relationship. Her verified filing blamed me alone and claimed she still did not know why the relationship ended. Her own emails, however, accused the vendor of backing out, stopping the business and shutting it down with three days’ notice. Those same emails stated that The Farmer’s Touch and A Farmer’s Touch at Home were “two different corporations” and that Widmann had “nothing to do with The Farmer’s Touch” that money was “between you and Charlene.” Yet in court, she attempted to connect that separate money to her own claim against me.

There was also an imbalance in how the two self-represented parties were permitted to proceed. The transcript identifies both Widmann and me as pro se, but separately lists her sister, Monique Widmann, as “also present.” Her sister sat with her, organized exhibits and audibly supplied exhibit numbers during the proceeding. Widmann even responded, “Yes. Good secretary.” I objected to having a non-lawyer assisting a pro se litigant against me at counsel table, but my objection was overruled. I was left to manage my testimony, exhibits, objections and courtroom procedure entirely on my own while managing my emotions about all of it.

When I finally testified about what this litigation had done to my life and business, I explained that I had spent four years on a paper chase, had been forced to rebuild my professional life and had endured what I described as “reputational hell.” I told the court…

“There can’t be a breach if there was no full payment. I’ve been trying to say this for four years.”

I also described the repeated appearances, the time taken from work, the damage to my business and the personal toll of defending myself through COVID, my father’s death, a personal injury, resulting in a surgery, another hospital stay for an illness, another close family relative with a serious health condition. From where I stood, while I was giving this deeply personal account, the judge appeared to be dozing off. I cannot state what was happening internally, but that was my direct observation and the impression I was left with while trying to explain years of harm.

Day Two demonstrates the central problem with my experience in this court system… I presented the contradictions, compared Widmann’s claims with her own sworn admissions and challenged proof that did not match the dates or payment terms alleged in the complaint.

Yet the case was not narrowed to those fundamental issues. It continued through layers of confusion while I struggled to make the court focus on the evidence directly in front of it.