On August 17, 2021 a
Letter,Correspondence
was filed
involving a dispute between
Hello Living Developer Nostrand Llc,
Hello Nostrand Llc,
and
1580 Nostrand Mezz Llc,
Madison Realty Capital Lp,
for Commercial - Business Entity
in the District Court of Rockland County.
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LAW OFFICES OF
VICTOR A. WORMS
48 Wall Street, 750
NEW YORK, NY 10005
TELEPHONE: (212) 374-9590
FACSIMILE: (212) 591-6188
WEB: VICTORAWORMSPC.COM
WRITERS EMAIL
VWORMS@VICTORAWORMSPC.COM
November 23, 2021
VIA ECF AND EMAIL
Hon. Paul I. Marx
Justice
Supreme Court of the State of New York
County of Rockland
1 South Main Street
New City, New York 10956
Re: Hello Living Developer Nostrand LLC, et. al. v. 1580 Nostrand
Mezz, LLC, et. al.
Index No. 034885/2021
Dear Justice Marx:
My office is counsel for the plaintiffs in the above-referenced action. I am writing in
reference to the defendants’ motion to dismiss the claims in the plaintiffs’ complaint (Motion
Sequence No. 2).
The motion is returnable today, November 23, 2021. However, counsel for the parties
have agreed to adjourn the return date to December 17, 2021, with opposition papers due on
November 30, 2021, and reply papers due on December 16, 2021.
The stipulation is in the process of being executed and will be filed once that occurs.
Further, it is respectfully requested that the Court so orders the stipulation upon its filing.
Thank you for your attention to this matter.
Respectfully submitted,
Victor A. Worms
2
Document Filed Date
November 23, 2021
Case Filing Date
August 17, 2021
Category
Commercial - Business Entity
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LAW OFFICES OF VICTOR A. WORMS 48 Wall Street, 750 NEW YORK, NY 10005 TELEPHONE: (212) 374-9590 FACSIMILE: (212) 591-6188 WEB: VICTORAWORMSPC.COM WRITERS EMAIL VWORMS@VICTORAWORMSPC.COM November 23, 2021 VIA ECF AND EMAIL Hon. Paul I. Marx Justice Supreme Court of the State of New York County of Rockland 1 South Main Street New City, New York 10956 Re: Hello Living Developer Nostrand LLC, et. al. v. 1580 Nostrand Mezz, LLC, et. al. Index No. 034885/2021 Dear Justice Marx: My office is counsel for the plaintiffs in the above-referenced action. I am writing in reference to the defendants’ motion to dismiss the claims in the plaintiffs’ complaint (Motion Sequence No. 2). The motion is returnable today, November 23, 2021. However, counsel for the parties have agreed to adjourn the return date to December 17, 2021, with opposition papers due on November 30, 2021, and reply papers due on December 16, 2021. The stipulation is in the process of being executed and will be filed once that occurs. Further, it is respectfully requested that the Court so orders the stipulation upon its filing. Thank you for your attention to this matter. Respectfully submitted, Victor A. Worms 2