Preview
FILED: DUTCHESS COUNTY CLERK 03/10/2022 01:38 PM INDEX NO. 2021-51452
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 03/10/2022
EXHIBIT “A”
FILED: DUTCHESS COUNTY CLERK 03/10/2022 01:38 PM INDEX NO. 2021-51452
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 03/10/2022
GUN1LLA P. FAR[ NGER
(GUNfLLA PEREZ-FAR[NGER)
34 SOUTH BROADWAYr SUITE 71O
ATTORNEY AT LAW WHrrE PLAlNs, NEw YoRK 1O601
(914) 574-3708 PH
(914) 948-1800 F
FARINGERL.AWGGMAlL.COM
WWW.FARENGER-LAW.COM
January 26, 2022
Hon. Maria G. Rosa
Supreme Court of the State of New York
County of Dutchess
10 Market Street
Poughkeepsie, NY 12601
Re.: von der Lieth v. Giordano et al, Index No. 2021-51452
LETTER MOTION FOR EXTENTION OF TIME
Dear Judge Rosa,
As the Court will recall, the undersigned represents the Defendants in the above referenced
case, Barbara Giodano-Leonaggeo and Robert Leonaggeo.
As the Court knows, on today's date Plaintiff filed his documents in reply to his motion for
summary judgment and in opposition to our cross-motion. Therefore, under the rules of procedure
itis my understanding that our reply to Plaintiff's opposition to our cross-motion is due on February
7.
Unfortunately I will not be able to draft and submit our reply by that date. The reason for
this situation is that I am currently coping with serious illness in my immediate family, and in
addition I will be leaving the country on Friday for an important family matter that cannot be
postponed. I am a solo practitioner and have no colleague to take over in stead when faced with
my
deadlines that are impossible to meet .
Therefore itis my great hope that the Court will grant us a three-weeks extension of time to
submit our reply forthree weeks, until February 28, or for such time that the Court finds just and
FILED: DUTCHESS COUNTY CLERK 03/10/2022 01:38 PM INDEX NO. 2021-51452
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 03/10/2022
GUN LA P. FAR1NGER, EsQ.
..
proper. I will return on February 7 and itis my great hope that the Court will agree to at least a
week after that to allow enough time to prepare our motion papers. Under my difficult current
verf
circumstances I do not have the resources to draft the documents before I leave,
Thankyou in advance to your attention to this matter.
Very truly yo rs, .
. anger, s
Cc:
Anthony Carlini
2
FILED: DUTCHESS COUNTY CLERK 03/10/2022 01:38 PM INDEX NO. 2021-51452
NYSCEF DOC. NO. 84 RECEIVED
'' .INDEX' NYSCEF: 03/10/2022
FILED DÙTCHESS COUNTY CLERK 18 /2021 04 No. 2021-51452
: 10 / : 3.5 PM)
NYSCEF DOC. NO. 38 RECEIVED $YSCEF: 1.0/18/2021
h
·
.· . O U N TL LA P. FA R I NG ER
(GUNEL.L.A
PEREZfARINGER)
'
34 SOUTH BROADWAY. 84.11TE730
ATTOR NEY AT LAW . · . 1060t'
WHITE PLAINs, NEW YORK
(91 4)574-s70s Pu
F.
. (914) 948-1800
FARINGERLAWGGMAII...COM
www.mm seed-tAw.cow
Hon. Maria G. Rosa
Supreme Court of the State ofNewYork
County of Dutchess
10 Marke Street
Poughiceepsie, New York 12601
Re.: yoridGUL4h IEño l ï hidex3Nÿ 2021-5M52
Dear Judge Rosa
As the Court knows, I have very recently been retained Defendants Barbara Giordano-
by
Leonaggeo and Roger Leonaggeo, to represent them inthe above referenced case.
Our answer to the to the currently pending motion filedby Plaintiffis due on Thursday,
October 21.However, as a resultof having been so recently retained, inaddition.to the factthat I ,
have been on medical feave for the past several days due to a hand surgery, I i-equest 30 days
. . extension of time to submit our answeeng papers. Counsel for Plaintiff,Mr. Caitini, has graciously
consented tothis enlargement. .
Therefore, itis our great hope that the Court will grant usa 30-day extension of tirtie
to allow .
sufficienttime forme tofamiliarize myself with the case and prepare the answering papers.
Thankyou iriadvance for your attention to thismatter.
Xosa/LS-C
5tii·ia~ó
. " Grante
Adjournment.R ques
New Dated't M 31
OPPOSING
.
SIDE OR .
Ve trulyyours
.
FailureTo NOTlFY g,
COUNSEL May ResultIn SANCTIONS
um la P.Faringer, Esq
5
1 of 1
FILED: DUTCHESS COUNTY CLERK 03/10/2022 01:38 PM INDEX NO. 2021-51452
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 03/10/2022
G U N I LLA P. FA R I NG E R
(GUHll.J.A PEFEZ-FARENGEIO
34 SOLITH BROADWAY, SUITE 7 fo
ATTORNEY AT LAW warrE PLAINS. NEW YORK IOBOI
(914.) 574-3708 PH
(9)4) 948-t800 F
FARINGERLAW@GMAl L,.COM
WWW.FARINGER-LAW.COM
----..._.....-
._.----.- . .
November 19, 202.1
Hon. Maria G. Rosa
Supreme Court of the StateofNew York
Cotmty of Dutchess
10 Marke Street
Poughkeepsic, New York 12601
Re.; von derLieth v. Giordano St at Index No. 2021-51452
Dear Judge Rosa,
As the Court I representthe defendants in the above referenced case, Barbara Giordano-
knows,
Leonaggeo and Roger Leonaggeo.
We thank the courtfor grantingus an extensionof timeto answer themotion by theplaintiffcurrently
pending before the Court.
However, unfortunately our current circumstances are such thatwe are again compelled to ask the
Court's indulgence for a second extension oftime. The reason forthis requestis thatI again had to take a
medical leave, as theresultof a severe back attack that rendered me beddidden for almost a week and still
intennittently,and inaddition todebilitatingpain, thepowerful pain medication makes itimpossible towork.
I am a solo petitionerwith no colleague tostep in incase of my absence, and for each day Pm not
able to work the caseload keeps piling up. At thistime I am overwhelmed, and itissimply not possible for
clients'
me to draftmy opposition tothe motion, in a casewhichinvolves complex issuesof factand lawand
requires serious attention,by our current deadline nextTuesday, November 23. Under thesecircumstances it
would be an injusticeto my clientsifIwere not ableto spend the timeand attentionrequired tofullyrepresent
their interests.
Therefore, we respectfully request an extension of 30 days to submit our opposition papers, or for
such period of thetime that the Court deems justand proper.
We thank the Court for your attention to thismatter.
Very truly,yours,
urn 1 . Faringer, s
Ce: Anthony Carlini, Esq.
FILED: DUTCHESS COUNTY CLERK 03/10/2022 01:38 PM INDEX NO. 2021-51452
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 03/10/2022
FILED : APPELLATE DIVISION - 2ND DEPT 07 /2 2 02900930
6 /2 0 21 05 : 41 PM|
NV$0EF DOC }d1lGLA A R ING ER RECEIVED NYBCEF: D7/26/2021
(007/EW PNHNY#AtUNMN)
OU'TM BNOADWAY4 SOlTE 7 10
AT'ro RN EY AT LAW WHiÄE PLAl NS, New 10601
Yons
(e (4)B74-870B PH
(914) e40-1000 r
ARINGERI4AWGloNAli.00M
WWW#ANH LAW.o M
oly 224021
5upreme Court of theState ofNew York
Appellat9 Division: SecondDepartment .
j 45 Monroe Place
Brooldyn, New York 11201
Ve. MW2 Boldiñas1LI£%Gordano Leonaegno pfakDocket No 2Q2F00930
Dear Clerk of theCourt,
As the Court knows, Irepresent1he appellantin the abovereferenced Barbara Oiordano-
appeal,
Leonaggeo.
I su writingto requeston enlargement of time toperfectthe appeal,which is currentlydue on
July 27. The reason for thisrequest isthat alace Iwas retained Ms. Giordano Itave experienced
by
extreme personal with
difftoulties seriousillness and complications after in my immediate
surgery
family.This situationhas cause seriousdelay inmy work as I am asolo practitioner
andhaveno backup
in cases such as this.
I amin seriousneed for more time tobe able toproduce work
quality my olient,
and itismy hope thatthe Cquit willgränt me a 10-day extensionof time,or such time as theCourt
any
findsjust and proper.
Please advise whether this lettermotion is or
sufficient, if a formal notico of motion yeth
supportingdocuments isrequired. No previous requestfor enlargement has been made,
Thankyou foryour anticipatedattentionto thismatter,
truly urs,
"'"""
. . nillaP aringer,Esq,
To:
Stenger,Diamond & Glass,LLP
1136 Route 9
Wappingers Falls,New York 12590
Attorneys for Respondent
leaemailandNESCEFonly
FILED: DUTCHESS COUNTY CLERK 03/10/2022 01:38 PM INDEX NO. 2021-51452
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 03/10/2022
F ILED : DUT CHE S S COUNTY CL ERK 11 / 1 0 /2 0 2 1 0 5 t 13 INDEX NO . 2018-50487
PM)
NYSCEF UOC. NO. 186 RECEIVED NYSCEF: 11/10/2021
G UN W V FAR
toepuhetam-Fararnem½
LNSER
m
S4 SWidTH EhigADWAY, Amyg 7 th
AtteRNEV NT lüW NOV 1 0 2021 wteruse. asƒ me
&14) $74 97 ;PM
HON. MICHAEL G. HAYES aw
. Nosehbe9 0à)
**This is to acknowledgethe Court's
receiptof the subject
correspondence,as wellas AttorneyHagstrom's November 10, 2021 letter
- I-fun"1VII asFR Ettyes to the Court.Adjournment request granted.Defendants are directed
to
.Supreme C60tt sf the etate ofNew Vork eFileoppositionpapers on or beforeDecember 12, 2021.Plaintiffis
Cowity ofDut@ess directedto eFile
reply paperson.orbefore December 21, 2201. Pursuant
10 MaUket 5treet . to my Part Rules,
a working copy ofeFiled submissionsis to be submitted
foughk4epalAMew?wki2601 to my chambers. Adjournments are onlygrantedwith leaveof the Court.
SO ORDERED:
Dated: Poughkeepsie, New York
November 10, 2021
HON. MICHAEL G. HAYBS, A .S.C.
. DeaNudge Egype,
TÈ!0S A nee fepreaenig ne Defendanta in the abon gferenced casq, Bathar r pedano
Leonggeoed l¾gnr Leanggeo..
l¾nfiff'
As te Court ƒilliecaS, 6ur opposiH0tt h the s ordee to Stiow cause urrently
bëf'otsee Cowt isdue thiscondng.FridayE676thber it Theporpose arthiaconimenitati6n is ta
hudly request an putendon of $me for the subsidasien of our @swedgg gapers
The r.egaonfor.owriequestis.that thogrder4gneUa arregly an medied leare anjtnable
topreparetheoppositioodocùmentsiaoomydfancewith thecurrent deadIlne.Ima n goropraefittener .
withno celleagaetestepin incase of titness,arrdfor everý 8ay l am e&werking the unattended
my
caseloadis sapidly gecumutáting,
werespeptMlygguesta$0dgys'
e@use b$hen f°cQ%Èpprmtances e tensingg0ime
to sobe tønt qp¶Wøsitipa ur At@.;peried-of titneae the Couredeterminn We hawneaked outto
Plaintiffto request theirconsent toapurregest but We have received no answer,
An the Cowt knows ah appeaHu the within ease is chrtently!anding before theSatund
beparkhenjrgnder D9eketWa. f202140939. Th that case naintiff beakeady be6zt granted ette30
dys'
sten[¼on o time to subnp{ttieirá
pogdent's brie¶ and has recenny subfnitted i second
v
1 of 2 .
. .
FILED: DUTCHESS COUNTY CLERK 03/10/2022 01:38 PM INDEX NO. 2021-51452
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 03/10/2022
F ILED : DUT CHE SS COUNTY L TK 11 10 2 0 21 0 5 : 13 INDEX NO, 2018-50487
/ / _P_g
NYSGEF DOC. NO. 186 RECEIVED NYSCEF : 11/10/2021
$r N)LA F. EARIMSER, È$9,
3Duiays* in factthat ridfntiffis represented by a,1aw-firm
reqµest for a enlargement, spiteof the
with several attorneys famihr with andworking nitthe nese,
dreuinstances e¬ believe:that we shedId be gYänted an 4xtensioñ of dine to.
Under these
the peDdingmotion in theinterest ofrfus6ce, as we haye:Dot opposed either .
respondfo particularly
. ene ofBaintiff s requestsfora one4nanth extratime toprepare th(írrespondentistries
Ror itisgr geM opg htthe Court will Understand tor cunct difftoult
eas reasons,
us an extension oF30 or £6rsuth leigth of tirá¢hint theCourt fiildsjust
sihiatioñ and grant däys,
nd propèt, to Afe opt ahÃwet
Wethanlsthe Cottrein advance for your attentioFto thisatAtter
Oun a A Fatager . q. .
Ce
KateriHE$stroin, Es4
Sten by biatnond & 0lass, L1-P
Ma MSCF20ñly .
2 of 2
FILED: DUTCHESS COUNTY CLERK 03/10/2022 01:38 PM INDEX NO. 2021-51452
NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 03/10/2022
IF ILED : APPELLATE DIVIS ION - 2ND DEPT 12 /3 2021-00930
0 / 2 O2 1 03 : 35 PM|
NYSCEF DOc.Ctid N LLLA P. FA R 1N G E R RECEIVED NYSCEF:- 12/30/2021
(Gom LLA PEREZ-FAR:NGER)
34 SouTH BROADWAY, $UtTE 7 10
ATTORNEY AT LAW WHITE PLAINs, NEW YoRK 10601
(9t4) 574-3708 PH
(9I4) 948-1800 F
FARINGE RLAWGGMAIL.cokI
WWW-FAMINGER-LAW.coM
December 30, 2021
Clerk of the Court
Supreme Court of the State of New York
Appellate Division: Second Department
45 Monroe Place
Brooklyn, New York 11201
Re.: M-M2 RE Holdings 1, LLC y. Barbara Giordano-Leonaggeo et aL Docket No. 2021-00930
Dear Clerk of the Court,
This office represents the Defendants in the above referenced appeal. As the Court knows,
Plaintiff-Respondent submitted itsbrief on December 29, 2021, and therefore, pursuant to therules
of procedure our reply brief is due ten days thereafter.
This is torespectfully request a 30-day enlargement of time to submit our reply brief.The
reason for the request isthat I will be travelling outside the country for a family reunion thatwas
scheduled well before Plaintiff-Respondent was granted two 30-day extensions of time to submit
their brief.At the time I had no way of knowing that itwould conflict with the deadline for our reply
brief.
I thank you in advance for your anticipated attention to thismatter.
- rs,
Very truly y
unilla P, Faringer, Esq.
Preview
FILED: DUTCHESS COUNTY CLERK 03/10/2022 01:38 PM INDEX NO. 2021-51452 NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 03/10/2022 EXHIBIT “A” FILED: DUTCHESS COUNTY CLERK 03/10/2022 01:38 PM INDEX NO. 2021-51452 NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 03/10/2022 GUN1LLA P. FAR[ NGER (GUNfLLA PEREZ-FAR[NGER) 34 SOUTH BROADWAYr SUITE 71O ATTORNEY AT LAW WHrrE PLAlNs, NEw YoRK 1O601 (914) 574-3708 PH (914) 948-1800 F FARINGERL.AWGGMAlL.COM WWW.FARENGER-LAW.COM January 26, 2022 Hon. Maria G. Rosa Supreme Court of the State of New York County of Dutchess 10 Market Street Poughkeepsie, NY 12601 Re.: von der Lieth v. Giordano et al, Index No. 2021-51452 LETTER MOTION FOR EXTENTION OF TIME Dear Judge Rosa, As the Court will recall, the undersigned represents the Defendants in the above referenced case, Barbara Giodano-Leonaggeo and Robert Leonaggeo. As the Court knows, on today's date Plaintiff filed his documents in reply to his motion for summary judgment and in opposition to our cross-motion. Therefore, under the rules of procedure itis my understanding that our reply to Plaintiff's opposition to our cross-motion is due on February 7. Unfortunately I will not be able to draft and submit our reply by that date. The reason for this situation is that I am currently coping with serious illness in my immediate family, and in addition I will be leaving the country on Friday for an important family matter that cannot be postponed. I am a solo practitioner and have no colleague to take over in stead when faced with my deadlines that are impossible to meet . Therefore itis my great hope that the Court will grant us a three-weeks extension of time to submit our reply forthree weeks, until February 28, or for such time that the Court finds just and FILED: DUTCHESS COUNTY CLERK 03/10/2022 01:38 PM INDEX NO. 2021-51452 NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 03/10/2022 GUN LA P. FAR1NGER, EsQ. .. proper. I will return on February 7 and itis my great hope that the Court will agree to at least a week after that to allow enough time to prepare our motion papers. Under my difficult current verf circumstances I do not have the resources to draft the documents before I leave, Thankyou in advance to your attention to this matter. Very truly yo rs, . . anger, s Cc: Anthony Carlini 2 FILED: DUTCHESS COUNTY CLERK 03/10/2022 01:38 PM INDEX NO. 2021-51452 NYSCEF DOC. NO. 84 RECEIVED '' .INDEX' NYSCEF: 03/10/2022 FILED DÙTCHESS COUNTY CLERK 18 /2021 04 No. 2021-51452 : 10 / : 3.5 PM) NYSCEF DOC. NO. 38 RECEIVED $YSCEF: 1.0/18/2021 h · .· . O U N TL LA P. FA R I NG ER (GUNEL.L.A PEREZfARINGER) ' 34 SOUTH BROADWAY. 84.11TE730 ATTOR NEY AT LAW . · . 1060t' WHITE PLAINs, NEW YORK (91 4)574-s70s Pu F. . (914) 948-1800 FARINGERLAWGGMAII...COM www.mm seed-tAw.cow Hon. Maria G. Rosa Supreme Court of the State ofNewYork County of Dutchess 10 Marke Street Poughiceepsie, New York 12601 Re.: yoridGUL4h IEño l ï hidex3Nÿ 2021-5M52 Dear Judge Rosa As the Court knows, I have very recently been retained Defendants Barbara Giordano- by Leonaggeo and Roger Leonaggeo, to represent them inthe above referenced case. Our answer to the to the currently pending motion filedby Plaintiffis due on Thursday, October 21.However, as a resultof having been so recently retained, inaddition.to the factthat I , have been on medical feave for the past several days due to a hand surgery, I i-equest 30 days . . extension of time to submit our answeeng papers. Counsel for Plaintiff,Mr. Caitini, has graciously consented tothis enlargement. . Therefore, itis our great hope that the Court will grant usa 30-day extension of tirtie to allow . sufficienttime forme tofamiliarize myself with the case and prepare the answering papers. Thankyou iriadvance for your attention to thismatter. Xosa/LS-C 5tii·ia~ó . " Grante Adjournment.R ques New Dated't M 31 OPPOSING . SIDE OR . Ve trulyyours . FailureTo NOTlFY g, COUNSEL May ResultIn SANCTIONS um la P.Faringer, Esq 5 1 of 1 FILED: DUTCHESS COUNTY CLERK 03/10/2022 01:38 PM INDEX NO. 2021-51452 NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 03/10/2022 G U N I LLA P. FA R I NG E R (GUHll.J.A PEFEZ-FARENGEIO 34 SOLITH BROADWAY, SUITE 7 fo ATTORNEY AT LAW warrE PLAINS. NEW YORK IOBOI (914.) 574-3708 PH (9)4) 948-t800 F FARINGERLAW@GMAl L,.COM WWW.FARINGER-LAW.COM ----..._.....- ._.----.- . . November 19, 202.1 Hon. Maria G. Rosa Supreme Court of the StateofNew York Cotmty of Dutchess 10 Marke Street Poughkeepsic, New York 12601 Re.; von derLieth v. Giordano St at Index No. 2021-51452 Dear Judge Rosa, As the Court I representthe defendants in the above referenced case, Barbara Giordano- knows, Leonaggeo and Roger Leonaggeo. We thank the courtfor grantingus an extensionof timeto answer themotion by theplaintiffcurrently pending before the Court. However, unfortunately our current circumstances are such thatwe are again compelled to ask the Court's indulgence for a second extension oftime. The reason forthis requestis thatI again had to take a medical leave, as theresultof a severe back attack that rendered me beddidden for almost a week and still intennittently,and inaddition todebilitatingpain, thepowerful pain medication makes itimpossible towork. I am a solo petitionerwith no colleague tostep in incase of my absence, and for each day Pm not able to work the caseload keeps piling up. At thistime I am overwhelmed, and itissimply not possible for clients' me to draftmy opposition tothe motion, in a casewhichinvolves complex issuesof factand lawand requires serious attention,by our current deadline nextTuesday, November 23. Under thesecircumstances it would be an injusticeto my clientsifIwere not ableto spend the timeand attentionrequired tofullyrepresent their interests. Therefore, we respectfully request an extension of 30 days to submit our opposition papers, or for such period of thetime that the Court deems justand proper. We thank the Court for your attention to thismatter. Very truly,yours, urn 1 . Faringer, s Ce: Anthony Carlini, Esq. FILED: DUTCHESS COUNTY CLERK 03/10/2022 01:38 PM INDEX NO. 2021-51452 NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 03/10/2022 FILED : APPELLATE DIVISION - 2ND DEPT 07 /2 2 02900930 6 /2 0 21 05 : 41 PM| NV$0EF DOC }d1lGLA A R ING ER RECEIVED NYBCEF: D7/26/2021 (007/EW PNHNY#AtUNMN) OU'TM BNOADWAY4 SOlTE 7 10 AT'ro RN EY AT LAW WHiÄE PLAl NS, New 10601 Yons (e (4)B74-870B PH (914) e40-1000 r ARINGERI4AWGloNAli.00M WWW#ANH LAW.o M oly 224021 5upreme Court of theState ofNew York Appellat9 Division: SecondDepartment . j 45 Monroe Place Brooldyn, New York 11201 Ve. MW2 Boldiñas1LI£%Gordano Leonaegno pfakDocket No 2Q2F00930 Dear Clerk of theCourt, As the Court knows, Irepresent1he appellantin the abovereferenced Barbara Oiordano- appeal, Leonaggeo. I su writingto requeston enlargement of time toperfectthe appeal,which is currentlydue on July 27. The reason for thisrequest isthat alace Iwas retained Ms. Giordano Itave experienced by extreme personal with difftoulties seriousillness and complications after in my immediate surgery family.This situationhas cause seriousdelay inmy work as I am asolo practitioner andhaveno backup in cases such as this. I amin seriousneed for more time tobe able toproduce work quality my olient, and itismy hope thatthe Cquit willgränt me a 10-day extensionof time,or such time as theCourt any findsjust and proper. Please advise whether this lettermotion is or sufficient, if a formal notico of motion yeth supportingdocuments isrequired. No previous requestfor enlargement has been made, Thankyou foryour anticipatedattentionto thismatter, truly urs, "'""" . . nillaP aringer,Esq, To: Stenger,Diamond & Glass,LLP 1136 Route 9 Wappingers Falls,New York 12590 Attorneys for Respondent leaemailandNESCEFonly FILED: DUTCHESS COUNTY CLERK 03/10/2022 01:38 PM INDEX NO. 2021-51452 NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 03/10/2022 F ILED : DUT CHE S S COUNTY CL ERK 11 / 1 0 /2 0 2 1 0 5 t 13 INDEX NO . 2018-50487 PM) NYSCEF UOC. NO. 186 RECEIVED NYSCEF: 11/10/2021 G UN W V FAR toepuhetam-Fararnem½ LNSER m S4 SWidTH EhigADWAY, Amyg 7 th AtteRNEV NT lüW NOV 1 0 2021 wteruse. asƒ me &14) $74 97 ;PM HON. MICHAEL G. HAYES aw . Nosehbe9 0à) **This is to acknowledgethe Court's receiptof the subject correspondence,as wellas AttorneyHagstrom's November 10, 2021 letter - I-fun"1VII asFR Ettyes to the Court.Adjournment request granted.Defendants are directed to .Supreme C60tt sf the etate ofNew Vork eFileoppositionpapers on or beforeDecember 12, 2021.Plaintiffis Cowity ofDut@ess directedto eFile reply paperson.orbefore December 21, 2201. Pursuant 10 MaUket 5treet . to my Part Rules, a working copy ofeFiled submissionsis to be submitted foughk4epalAMew?wki2601 to my chambers. Adjournments are onlygrantedwith leaveof the Court. SO ORDERED: Dated: Poughkeepsie, New York November 10, 2021 HON. MICHAEL G. HAYBS, A .S.C. . DeaNudge Egype, TÈ!0S A nee fepreaenig ne Defendanta in the abon gferenced casq, Bathar r pedano Leonggeoed l¾gnr Leanggeo.. l¾nfiff' As te Court ƒilliecaS, 6ur opposiH0tt h the s ordee to Stiow cause urrently bëf'otsee Cowt isdue thiscondng.FridayE676thber it Theporpose arthiaconimenitati6n is ta hudly request an putendon of $me for the subsidasien of our @swedgg gapers The r.egaonfor.owriequestis.that thogrder4gneUa arregly an medied leare anjtnable topreparetheoppositioodocùmentsiaoomydfancewith thecurrent deadIlne.Ima n goropraefittener . withno celleagaetestepin incase of titness,arrdfor everý 8ay l am e&werking the unattended my caseloadis sapidly gecumutáting, werespeptMlygguesta$0dgys' e@use b$hen f°cQ%Èpprmtances e tensingg0ime to sobe tønt qp¶Wøsitipa ur At@.;peried-of titneae the Couredeterminn We hawneaked outto Plaintiffto request theirconsent toapurregest but We have received no answer, An the Cowt knows ah appeaHu the within ease is chrtently!anding before theSatund beparkhenjrgnder D9eketWa. f202140939. Th that case naintiff beakeady be6zt granted ette30 dys' sten[¼on o time to subnp{ttieirá pogdent's brie¶ and has recenny subfnitted i second v 1 of 2 . . . FILED: DUTCHESS COUNTY CLERK 03/10/2022 01:38 PM INDEX NO. 2021-51452 NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 03/10/2022 F ILED : DUT CHE SS COUNTY L TK 11 10 2 0 21 0 5 : 13 INDEX NO, 2018-50487 / / _P_g NYSGEF DOC. NO. 186 RECEIVED NYSCEF : 11/10/2021 $r N)LA F. EARIMSER, È$9, 3Duiays* in factthat ridfntiffis represented by a,1aw-firm reqµest for a enlargement, spiteof the with several attorneys famihr with andworking nitthe nese, dreuinstances e¬ believe:that we shedId be gYänted an 4xtensioñ of dine to. Under these the peDdingmotion in theinterest ofrfus6ce, as we haye:Dot opposed either . respondfo particularly . ene ofBaintiff s requestsfora one4nanth extratime toprepare th(írrespondentistries Ror itisgr geM opg htthe Court will Understand tor cunct difftoult eas reasons, us an extension oF30 or £6rsuth leigth of tirá¢hint theCourt fiildsjust sihiatioñ and grant däys, nd propèt, to Afe opt ahÃwet Wethanlsthe Cottrein advance for your attentioFto thisatAtter Oun a A Fatager . q. . Ce KateriHE$stroin, Es4 Sten by biatnond & 0lass, L1-P Ma MSCF20ñly . 2 of 2 FILED: DUTCHESS COUNTY CLERK 03/10/2022 01:38 PM INDEX NO. 2021-51452 NYSCEF DOC. NO. 84 RECEIVED NYSCEF: 03/10/2022 IF ILED : APPELLATE DIVIS ION - 2ND DEPT 12 /3 2021-00930 0 / 2 O2 1 03 : 35 PM| NYSCEF DOc.Ctid N LLLA P. FA R 1N G E R RECEIVED NYSCEF:- 12/30/2021 (Gom LLA PEREZ-FAR:NGER) 34 SouTH BROADWAY, $UtTE 7 10 ATTORNEY AT LAW WHITE PLAINs, NEW YoRK 10601 (9t4) 574-3708 PH (9I4) 948-1800 F FARINGE RLAWGGMAIL.cokI WWW-FAMINGER-LAW.coM December 30, 2021 Clerk of the Court Supreme Court of the State of New York Appellate Division: Second Department 45 Monroe Place Brooklyn, New York 11201 Re.: M-M2 RE Holdings 1, LLC y. Barbara Giordano-Leonaggeo et aL Docket No. 2021-00930 Dear Clerk of the Court, This office represents the Defendants in the above referenced appeal. As the Court knows, Plaintiff-Respondent submitted itsbrief on December 29, 2021, and therefore, pursuant to therules of procedure our reply brief is due ten days thereafter. This is torespectfully request a 30-day enlargement of time to submit our reply brief.The reason for the request isthat I will be travelling outside the country for a family reunion thatwas scheduled well before Plaintiff-Respondent was granted two 30-day extensions of time to submit their brief.At the time I had no way of knowing that itwould conflict with the deadline for our reply brief. I thank you in advance for your anticipated attention to thismatter. - rs, Very truly y unilla P, Faringer, Esq.