Motion-Secondary: Hello Living Developer Nostrand Llc, Hello Nostrand Llc v. 1580 Nostrand Mezz Llc, Madison Realty Capital Lp

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                                FILED:         ROCKLAND           COUNTY        CLERK        12/11/2021             12:46        AM                 INDEX    NO.   034885/2021
   NYSCEF     DOC.   NO.   85                                                                                 RECEIVED      NYSCEF:     12/11/2021




                  SUPREME COURT OF THE STATE OF NEW YORK
                  COUNTY OF ROCKLAND
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                  HELLO LIVING DEVELOPER NOSTRAND LLC and                                          Index No. 034885/2021
                  HELLO NOSTRAND LLC,


                                    Plaintiffs,                                             AFFIRMATION OF
                                                                                            VICTOR A. WORMS IN
                     -against-                                                              IN SUPPORT OF PLAINTIFFS’
                                                                                            MOTION FOR A STAY
                  1580 NOSTRAND MEZZ, LLC,
                  MADISON REALTY CAPITAL, L.P.,

                                    Defendants.

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                           I, Victor A. Worms, affirm under the penalty of perjury that:

                           1.  I am an attorney admitted to practice law in the State of New York, and that I am the

                  attorney for the plaintiffs in this action.

                           2.  I submit this affirmation in support of the plaintiffs’ motion for a stay, pursuant

                  to CPLR 2201, of the Court’s order of October 25, 2021, suspending the notice of sale dated

                  October 20, 2021, of plaintiff      Hello Living Developer Nostrand, LLC’s 100% membership

                  interests in plaintiff Hello Nostrand LLC (the “Collateral”) and suspending the UCC

                  foreclosure sale of the Collateral scheduled for December 22, 2021, at 2 p.m. (the

                  “Auction”) and (ii) granting such other and further relief as this Court deems just and

                  proper.

                           3.  Annexed hereto as Exhibit “A” is a true and correct copy of the summons and

                  verified complaint in this action.




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   FILED:         ROCKLAND           COUNTY        CLERK        12/11/2021             12:46        AM                 INDEX    NO.   034885/2021
   NYSCEF     DOC.   NO.   85                                                                                 RECEIVED      NYSCEF:     12/11/2021




                           4.  Annexed hereto as Exhibit “B” is a true and correct copy of the Court’s August 24,

                  2021 Order of the Court.

                           5.  Annexed hereto as Exhibit “C” is a true and correct copy of the Court’s October 25,

                  2021 order.

                           6.  Annexed hereto as Exhibit “D” is a true and correct copy of the notice of sale of the

                  Collateral dated October 20, 2021.

                  Dated: New York, New York
                           December 10, 2021



                                                                                        _____________________
                                                                                          Victor A. Worms




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