It is not a big surprise that Ortiz v Joel J. Turney, LLC  2019 NY Slip Op 03917 [172 AD3d 553] May 21, 2019 Appellate Division, First Department is defended pro-se.  It is surprising that this case went to an appeal.  Here is the short and sweet decision:

“Defendants’ letter to plaintiff, in which they admit that plaintiff’s underlying property damage action was not timely commenced and state that they will “willingly compensate [him] for all actual damages subject to proof and interest since the time of the loss,” constitutes an admission of defendants’ negligence and that it was the proximate cause of plaintiff’s loss (see Marchi Jaffe Cohen Crystal Rosner & Katz v All-Star Video Corp., 107 AD2d 597 [1st Dept 1985]; see generally Leder v Spiegel, 31 AD3d 266, 267-268 [1st Dept 2006], affd 9 NY3d 836 [2007], cert denied 552 US 1257 [2008]). Contrary to defendants’ contentions, the language of the letter cannot be interpreted in any other manner.”