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 30, 2022
VIA NYSCEF
Hon. Lawrence Knipel, J.S.C.
Kings County Courthouse
360 Adams Street, Room 774
Brooklyn, New York 11201
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. This is to advise the Court that the Order
to Show Cause you entered on September 19, 2022 (NYSCEF Doc. No. 141) remains pending
because counsel for Nostrand Mezz Lender LLC, despite her statements on the record that
Nostrand Mezz Lender LLC agreed to be added as a party defendant, refuses to consider the draft
proposed Order sent to her today. See attached email.
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)
800 Third Avenue ï‚· 11th Floor ï‚· New York, NY 10022
www.kudmanlaw.com ï‚· Main (212) 868-1010
Document Filed Date
September 30, 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 30, 2022 VIA NYSCEF Hon. Lawrence Knipel, J.S.C. Kings County Courthouse 360 Adams Street, Room 774 Brooklyn, New York 11201 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. This is to advise the Court that the Order to Show Cause you entered on September 19, 2022 (NYSCEF Doc. No. 141) remains pending because counsel for Nostrand Mezz Lender LLC, despite her statements on the record that Nostrand Mezz Lender LLC agreed to be added as a party defendant, refuses to consider the draft proposed Order sent to her today. See attached email. 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) 800 Third Avenue  11th Floor  New York, NY 10022 www.kudmanlaw.com  Main (212) 868-1010