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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Francis M. Curran Direct (212) 868–0871 fcurran@kudmanlaw.com
Admitted in NY, NJ, and FL
September 19, 2022
VIA NYSCEF AND EMAIL
Hon. Paul I. Marx, J.S.C.
Rockland County Courthouse
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
Your Honor:
This firm is co-counsel for plaintiffs in this matter. As outlined in the attached Emergency
Affirmation of Paul H. Aloe, Esq., Court intervention is needed on an emergency basis. Plaintiffs
filed their application for an Order to Show Cause on September 16, 2022, immediately after
plaintiffs learned of misleading information in the data room maintained for the UCC sale that has
been scheduled for September 21, 2022. The bid deadline has been set for today, September 19,
2022.
Plaintiffs respectfully request the TRO be entered on an emergency basis and are available
for a “Teams” conference at any time at the Court’s direction.
Thank you for your consideration of this request. Please let counsel know if you have any
questions or need any additional information.
Respectfully submitted,
/s/ Francis M. Curran
Francis M. Curran
cc: Counsel of record (via NYSCEF)
Cory M. Gray, Esq. (via email)
Gayle Pollack, Esq. (via email)
800 Third Avenue 11th Floor New York, NY 10022
www.kudmanlaw.com Main (212) 868-1010
Document Filed Date
September 19, 2022
Case Filing Date
August 17, 2021
Category
Commercial - Business Entity
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Francis M. Curran Direct (212) 868–0871 fcurran@kudmanlaw.com Admitted in NY, NJ, and FL September 19, 2022 VIA NYSCEF AND EMAIL Hon. Paul I. Marx, J.S.C. Rockland County Courthouse 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 Your Honor: This firm is co-counsel for plaintiffs in this matter. As outlined in the attached Emergency Affirmation of Paul H. Aloe, Esq., Court intervention is needed on an emergency basis. Plaintiffs filed their application for an Order to Show Cause on September 16, 2022, immediately after plaintiffs learned of misleading information in the data room maintained for the UCC sale that has been scheduled for September 21, 2022. The bid deadline has been set for today, September 19, 2022. Plaintiffs respectfully request the TRO be entered on an emergency basis and are available for a “Teams” conference at any time at the Court’s direction. Thank you for your consideration of this request. Please let counsel know if you have any questions or need any additional information. Respectfully submitted, /s/ Francis M. Curran Francis M. Curran cc: Counsel of record (via NYSCEF) Cory M. Gray, Esq. (via email) Gayle Pollack, Esq. (via email) 800 Third Avenue 11th Floor New York, NY 10022 www.kudmanlaw.com Main (212) 868-1010