On August 17, 2021 a
Motion,Ex Parte
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.
Preview
FILED: ROCKLAND COUNTY CLERK 12/11/2021 12:46 AM INDEX NO. 034885/2021
NYSCEF DOC. NO. 90 RECEIVED NYSCEF: 12/11/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ROCKLAND
---------------------------------------------------------------------X
HELLO LIVING DEVELOPER NOSTRAND LLC and Index No. 034885/2021
HELLO NOSTRAND LLC,
Plaintiffs, AFFIRMATION OF
VICTOR A. WORMS IN
-against- IN ACCORDANCE WITH
NYCRR 202.7
1580 NOSTRAND MEZZ, LLC,
MADISON REALTY CAPITAL, L.P.,
Defendants.
-------------------------------------------------------------------- X
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. On December 9, 2021, I notified counsel for the Defendants of my intention to
present the filing of an order to show cause seeking a stay in this action. The notification was
made via email directly to the Defendants’ counsel. A copy of that communication is attached
hereto as Exhibit “A.”
Dated: New York, New York
December 10, 2021
_____________________
Victor A. Worms
1 of 3
FILED: ROCKLAND COUNTY CLERK 12/11/2021 12:46 AM INDEX NO. 034885/2021
NYSCEF DOC. NO. 90 RECEIVED NYSCEF: 12/11/2021
EXHIBIT “A”
2 of 3
FILED: ROCKLAND COUNTY CLERK 12/11/2021 12:46 AM INDEX NO. 034885/2021
NYSCEF DOC. NO. 90 RECEIVED NYSCEF: 12/11/2021
LAW OFFICES OF
VICTOR A. WORMS
48 Wall Street, SUITE 1100
NEW YORK, NY 10005
TELEPHONE: (212) 374-9590
FACSIMILE: (212) 591-6188
WEB: VICTORAWORMSPC.COM
WRITERS EMAIL
VWORMS@VICTORAWORMSPC.COM
December 9, 2021
VIA E-MAIL
Michael Bonneville, Esq.
Kriss & Feuerstein LLP
360 Lexington Avenue
New York, New York 10017 .
Re: Hello Living Developer Nostrand LLC, et. al. v.
1580 Nostrand Mezz LLC, et. al.
Supreme Court, Rockland County
Index No. 034885/2021
Dear Mr. Bonneville:
As you are aware, my office represents the plaintiffs in the above-referenced action. I am
writing to inform you that I intend to present to the Court an order to show cause for signature on
Friday, December 10, 2021, at 4:30 PM or soon thereafter as the Court may be heard on the
matter.
You will be provided with a copy of the order to show cause at the time of its filing.
Sincerely,
Victor A. Worms
3 of 3
Document Filed Date
December 11, 2021
Case Filing Date
August 17, 2021
Category
Commercial - Business Entity
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FILED: ROCKLAND COUNTY CLERK 12/11/2021 12:46 AM INDEX NO. 034885/2021 NYSCEF DOC. NO. 90 RECEIVED NYSCEF: 12/11/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ROCKLAND ---------------------------------------------------------------------X HELLO LIVING DEVELOPER NOSTRAND LLC and Index No. 034885/2021 HELLO NOSTRAND LLC, Plaintiffs, AFFIRMATION OF VICTOR A. WORMS IN -against- IN ACCORDANCE WITH NYCRR 202.7 1580 NOSTRAND MEZZ, LLC, MADISON REALTY CAPITAL, L.P., Defendants. -------------------------------------------------------------------- X 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. On December 9, 2021, I notified counsel for the Defendants of my intention to present the filing of an order to show cause seeking a stay in this action. The notification was made via email directly to the Defendants’ counsel. A copy of that communication is attached hereto as Exhibit “A.” Dated: New York, New York December 10, 2021 _____________________ Victor A. Worms 1 of 3 FILED: ROCKLAND COUNTY CLERK 12/11/2021 12:46 AM INDEX NO. 034885/2021 NYSCEF DOC. NO. 90 RECEIVED NYSCEF: 12/11/2021 EXHIBIT “A” 2 of 3 FILED: ROCKLAND COUNTY CLERK 12/11/2021 12:46 AM INDEX NO. 034885/2021 NYSCEF DOC. NO. 90 RECEIVED NYSCEF: 12/11/2021 LAW OFFICES OF VICTOR A. WORMS 48 Wall Street, SUITE 1100 NEW YORK, NY 10005 TELEPHONE: (212) 374-9590 FACSIMILE: (212) 591-6188 WEB: VICTORAWORMSPC.COM WRITERS EMAIL VWORMS@VICTORAWORMSPC.COM December 9, 2021 VIA E-MAIL Michael Bonneville, Esq. Kriss & Feuerstein LLP 360 Lexington Avenue New York, New York 10017 . Re: Hello Living Developer Nostrand LLC, et. al. v. 1580 Nostrand Mezz LLC, et. al. Supreme Court, Rockland County Index No. 034885/2021 Dear Mr. Bonneville: As you are aware, my office represents the plaintiffs in the above-referenced action. I am writing to inform you that I intend to present to the Court an order to show cause for signature on Friday, December 10, 2021, at 4:30 PM or soon thereafter as the Court may be heard on the matter. You will be provided with a copy of the order to show cause at the time of its filing. Sincerely, Victor A. Worms 3 of 3