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.