Preview
FILED: KINGS COUNTY CLERK 06/14/2021 10:56 AM INDEX NO. 510798/2018
NYSCEF DOC. NO. 262 RECEIVED NYSCEF: 06/14/2021
KEIDEL, WELDON & CUNNINGHAM, LLP
ATTORNEYS AT LAW
925 Westchester Avenue
Suite 400
White Plains, New York 10604
Telephone: (914) 948‐7000
Telefax: (914) 948‐7010 (Not for Service)
http://www.kwcllp.com
June 11, 2021
L. Blake Morris, Esq.
1214 Cortelyou Rd.
Brooklyn, NY 12218-5404
RE: Atlantic Casualty Insurance Company v. Eastern Fruit & Vegetables Inc.
File No. 11999
Dear Mr. Morris:
As I advised by email, please be advised that, on behalf of Atlantic Casualty Insurance
Company, we intend to file an order to show cause with the Court on Monday, June 14, 2021
requesting the reliefs reflected in the enclosed.
Very truly yours,
Debra M. Krebs
WHITE PLAINS, NY NEW YORK, NY SYRACUSE, NY
WILTON, CT WARWICK, RI WYNCOTE, PA
FAIR LAWN, NJ WILLISTON, VT NAPLES, FL
FILED: KINGS COUNTY CLERK 06/14/2021 10:56 AM INDEX NO. 510798/2018
NYSCEF DOC. NO. 262 RECEIVED NYSCEF: 06/14/2021
At IAS Part of the Supreme Court of the State of
New York, held in and for the County of Kings at the
Courthouse thereof located at 360 Adams Street,
Brooklyn, New York on , 2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
ATLANTIC CASUALTY INSURANCE Index No.: 510798/2018
COMPANY,
Plaintiff, ORDER TO SHOW CAUSE
v.
EASTERN FRUIT & VEGETABLES INC.
Defendant.
Upon reading and filing the annexed affirmations of Debra M. Krebs, Esq., dated
June __, 2021 with exhibits, and the accompanying memorandum of law, and upon all the prior
pleadings and proceedings heretofore had herein;
LET DEFENDANT EASTERN FRUIT & VEGETABLES INC. show cause before the
Supreme Court of Kings County, IAS Part , Room , at the courthouse located at 360
Adams Street, Brooklyn, New York on , 2021, at 9:30 a.m. or as soon
thereafter as counsel can be heard, why an order should not be made and entered,
a) pursuant to CPLR 2304 to quash the subpoena which Defendant served upon Hull
& Co., Inc. (“Hull”) on the basis that it is identical to a subpoena previously served
upon Hull and to which Hull responded on or about April 14, 2021; and/or
b) pursuant to CPLR 3216 striking Defendant’s Demand to File Note of Issue, filed
with this Court on March 19, 2021 [NYSCEF Doc. No. 195 because, on
June 7, 2021 Defendant notified the undersigned that on May 19, 2021 Defendant
1
FILED: KINGS COUNTY CLERK 06/14/2021 10:56 AM INDEX NO. 510798/2018
NYSCEF DOC. NO. 262 RECEIVED NYSCEF: 06/14/2021
served a subpoena on Hull & Co., Inc. returnable after the note of issue deadline
set by this Court; and/or
c) pursuant to CPLR 2204 and/or CPLR 3216 and/or 22 NYCRR § 202.21(d),
extending Atlantic Casualty Insurance Company’s (“Atlantic Casualty”) time to
file a note of issue and certificate of readiness; and
d) Pursuant to 22 NYCRR § 130-1.2 awarding Atlantic Casualty the costs associated
with having to make this motion and imposing sanctions upon Defendant for its
frivolous conduct in (i) serving a subpoena returnable after the note of issue
deadline; (ii) refusing to speak with the undersigned to address their position with
respect to the impact of Defendant’s pending subpoena on Atlantic Casualty’s
ability to file the note of issue and/or whether the note of issue deadline should be
extended; and (iii) abruptly hanging up on and refusing to speak with the
undersigned to address this issue; and
e) Pursuant to CPLR 3025 seeking to amend the ad damnum clause in the Complaint
in light of documents received by the undersigned on June 9, 2021; and
b) Granting Atlantic Casualty such other, further and different relief to plaintiff as this
court deems just, equitable and proper; and it is further
ORDERED that the deadline for Atlantic Casualty to file and serve a note of issue in this
action, in particular any deadline pursuant to Defendant’s Demand to File Note of Issue as well as
any other such deadline, to the extent necessary, be stayed and/or extended pending the hearing
and determination of this motion; and it is further
ORDERED that service of a copy of this Order to Show Cause, and the papers upon which
it is based, upon Defendant Eastern Fruit & Vegetables Inc., through its counsel, by filing a copy
2
FILED: KINGS COUNTY CLERK 06/14/2021 10:56 AM INDEX NO. 510798/2018
NYSCEF DOC. NO. 262 RECEIVED NYSCEF: 06/14/2021
of this Order to Show Cause with Notice of Entry on the docket in NYSCEF. Such service shall
be deemed timely if the Order to Show Cause with Notice of Entry is filed on or before
June ___, 2021. Any opposition to this Order to Show Cause shall be filed on NYSCEF on or
before _______________, 2021. Any reply to such opposition shall be filed on NYSCEF on or
before ________________, 2021.
E N T E R:
Hon.
3
FILED: KINGS COUNTY CLERK 06/14/2021 10:56 AM INDEX NO. 510798/2018
NYSCEF DOC. NO. 262 RECEIVED NYSCEF: 06/14/2021
From: Debra Krebs
To: blake@lblakemorris.com; info@lblakemorris.com
Subject: RE: Atlantic Casualty v. Eastern Fruit
Date: Friday, June 11, 2021 9:23:00 AM
Attachments: OSC.pdf
Please note that we have changed the filing date/time. An order to show cause requesting the relief
requested in the attached will be filed on Monday, June 7, 2021 at 10:00 am or as soon thereafter as
we are able to do so.
Debbie Krebs
Debra M. Krebs, Esq.
Keidel, Weldon & Cunningham, LLP
925 Westchester Avenue
Suite 400
White Plains, NY 10604
Tel: (914) 948-7000
(201) 490-7706
Fax: (914) 948-7010
dkrebs@kwcllp.com
Confidentiality: The information contained in this e-mail message is intended only for the
use of the individual or entity named above and is privileged and confidential. Any
dissemination, distribution, or copy of this communication other than to the individual or
entity named above is strictly prohibited. If you have received this communication in error,
please notify us immediately by telephone.
From: Debra Krebs
Sent: Thursday, June 10, 2021 4:45 PM
To: blake@lblakemorris.com; info@lblakemorris.com
Subject: RE: Atlantic Casualty v. Eastern Fruit
It appears there was a clerical error in the prior notice. Please see attached. The request for
temporary relief is unchanged. Please be advised that we intend to file the order to show cause on
June 11, 2021 at 10:00 am or as soon thereafter as we are able to do so.
Debbie Krebs
Debra M. Krebs, Esq.
Keidel, Weldon & Cunningham, LLP
925 Westchester Avenue
Suite 400
White Plains, NY 10604
Tel: (914) 948-7000
(201) 490-7706
Fax: (914) 948-7010
dkrebs@kwcllp.com
FILED: KINGS COUNTY CLERK 06/14/2021 10:56 AM INDEX NO. 510798/2018
NYSCEF DOC. NO. 262 RECEIVED NYSCEF: 06/14/2021
Confidentiality: The information contained in this e-mail message is intended only for the
use of the individual or entity named above and is privileged and confidential. Any
dissemination, distribution, or copy of this communication other than to the individual or
entity named above is strictly prohibited. If you have received this communication in error,
please notify us immediately by telephone.
From: Debra Krebs
Sent: Thursday, June 10, 2021 3:49 PM
To: blake@lblakemorris.com; info@lblakemorris.com
Subject: Atlantic Casualty v. Eastern Fruit
Please be advised that, since you have hung up on me and refused to address your position
regarding your pending subpoena on the note of issue we need to file in this matter and/or whether
an extension should be obtained, we are being forced to file the attached order to show cause and
to request the temporary relief being sought therein. We intend to file the order to show cause on
June 11, 2021 at 10:00 am or as soon thereafter as we are able to do so.
Debbie Krebs
Debra M. Krebs, Esq.
Keidel, Weldon & Cunningham, LLP
925 Westchester Avenue
Suite 400
White Plains, NY 10604
Tel: (914) 948-7000
(201) 490-7706
Fax: (914) 948-7010
dkrebs@kwcllp.com
Confidentiality: The information contained in this e-mail message is intended only for the
use of the individual or entity named above and is privileged and confidential. Any
dissemination, distribution, or copy of this communication other than to the individual or
entity named above is strictly prohibited. If you have received this communication in error,
please notify us immediately by telephone.
FILED: KINGS COUNTY CLERK 06/14/2021 10:56 AM INDEX NO. 510798/2018
NYSCEF DOC. NO. 262 RECEIVED NYSCEF: 06/14/2021
At IAS Part of the Supreme Court of the State of
New York, held in and for the County of Kings at the
Courthouse thereof located at 360 Adams Street,
Brooklyn, New York on , 2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
ATLANTIC CASUALTY INSURANCE Index No.: 510798/2018
COMPANY,
Plaintiff, ORDER TO SHOW CAUSE
v.
EASTERN FRUIT & VEGETABLES INC.
Defendant.
Upon reading and filing the annexed affirmations of Debra M. Krebs, Esq., dated
June __, 2021 with exhibits, and the accompanying memorandum of law, and upon all the prior
pleadings and proceedings heretofore had herein;
LET DEFENDANT EASTERN FRUIT & VEGETABLES INC. show cause before the
Supreme Court of Kings County, IAS Part , Room , at the courthouse located at 360
Adams Street, Brooklyn, New York on , 2021, at 9:30 a.m. or as soon
thereafter as counsel can be heard, why an order should not be made and entered,
a) pursuant to CPLR 2304 to quash the subpoena which Defendant served upon Hull
& Co., Inc. (“Hull”) on the basis that it is identical to a subpoena previously served
upon Hull and to which Hull responded on or about April 14, 2021; and/or
b) pursuant to CPLR 3216 striking Defendant’s Demand to File Note of Issue, filed
with this Court on March 19, 2021 [NYSCEF Doc. No. 195 because, on
June 7, 2021 Defendant notified the undersigned that on May 19, 2021 Defendant
1
FILED: KINGS COUNTY CLERK 06/14/2021 10:56 AM INDEX NO. 510798/2018
NYSCEF DOC. NO. 262 RECEIVED NYSCEF: 06/14/2021
served a subpoena on Hull & Co., Inc. returnable after the note of issue deadline
set by this Court; and/or
c) pursuant to CPLR 2204 and/or CPLR 3216 and/or 22 NYCRR § 202.21(d),
extending Atlantic Casualty Insurance Company’s (“Atlantic Casualty”) time to
file a note of issue and certificate of readiness; and
d) Pursuant to 22 NYCRR § 130-1.2 awarding Atlantic Casualty the costs associated
with having to make this motion and imposing sanctions upon Defendant for its
frivolous conduct in (i) serving a subpoena returnable after the note of issue
deadline; (ii) refusing to speak with the undersigned to address their position with
respect to the impact of Defendant’s pending subpoena on Atlantic Casualty’s
ability to file the note of issue and/or whether the note of issue deadline should be
extended; and (iii) abruptly hanging up on and refusing to speak with the
undersigned to address this issue; and
e) Pursuant to CPLR 3025 seeking to amend the ad damnum clause in the Complaint
in light of documents received by the undersigned on June 9, 2021; and
b) Granting Atlantic Casualty such other, further and different relief to plaintiff as this
court deems just, equitable and proper; and it is further
ORDERED that the deadline for Atlantic Casualty to file and serve a note of issue in this
action, in particular any deadline pursuant to Defendant’s Demand to File Note of Issue as well as
any other such deadline, to the extent necessary, be stayed and/or extended pending the hearing
and determination of this motion; and it is further
ORDERED that service of a copy of this Order to Show Cause, and the papers upon which
it is based, upon Defendant Eastern Fruit & Vegetables Inc., through its counsel, by filing a copy
2
FILED: KINGS COUNTY CLERK 06/14/2021 10:56 AM INDEX NO. 510798/2018
NYSCEF DOC. NO. 262 RECEIVED NYSCEF: 06/14/2021
of this Order to Show Cause with Notice of Entry on the docket in NYSCEF. Such service shall
be deemed timely if the Order to Show Cause with Notice of Entry is filed on or before
June ___, 2021. Any opposition to this Order to Show Cause shall be filed on NYSCEF on or
before _______________, 2021. Any reply to such opposition shall be filed on NYSCEF on or
before ________________, 2021.
E N T E R:
Hon.
3
Preview
FILED: KINGS COUNTY CLERK 06/14/2021 10:56 AM INDEX NO. 510798/2018 NYSCEF DOC. NO. 262 RECEIVED NYSCEF: 06/14/2021 KEIDEL, WELDON & CUNNINGHAM, LLP ATTORNEYS AT LAW 925 Westchester Avenue Suite 400 White Plains, New York 10604 Telephone: (914) 948‐7000 Telefax: (914) 948‐7010 (Not for Service) http://www.kwcllp.com June 11, 2021 L. Blake Morris, Esq. 1214 Cortelyou Rd. Brooklyn, NY 12218-5404 RE: Atlantic Casualty Insurance Company v. Eastern Fruit & Vegetables Inc. File No. 11999 Dear Mr. Morris: As I advised by email, please be advised that, on behalf of Atlantic Casualty Insurance Company, we intend to file an order to show cause with the Court on Monday, June 14, 2021 requesting the reliefs reflected in the enclosed. Very truly yours, Debra M. Krebs WHITE PLAINS, NY NEW YORK, NY SYRACUSE, NY WILTON, CT WARWICK, RI WYNCOTE, PA FAIR LAWN, NJ WILLISTON, VT NAPLES, FL FILED: KINGS COUNTY CLERK 06/14/2021 10:56 AM INDEX NO. 510798/2018 NYSCEF DOC. NO. 262 RECEIVED NYSCEF: 06/14/2021 At IAS Part of the Supreme Court of the State of New York, held in and for the County of Kings at the Courthouse thereof located at 360 Adams Street, Brooklyn, New York on , 2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ATLANTIC CASUALTY INSURANCE Index No.: 510798/2018 COMPANY, Plaintiff, ORDER TO SHOW CAUSE v. EASTERN FRUIT & VEGETABLES INC. Defendant. Upon reading and filing the annexed affirmations of Debra M. Krebs, Esq., dated June __, 2021 with exhibits, and the accompanying memorandum of law, and upon all the prior pleadings and proceedings heretofore had herein; LET DEFENDANT EASTERN FRUIT & VEGETABLES INC. show cause before the Supreme Court of Kings County, IAS Part , Room , at the courthouse located at 360 Adams Street, Brooklyn, New York on , 2021, at 9:30 a.m. or as soon thereafter as counsel can be heard, why an order should not be made and entered, a) pursuant to CPLR 2304 to quash the subpoena which Defendant served upon Hull & Co., Inc. (“Hull”) on the basis that it is identical to a subpoena previously served upon Hull and to which Hull responded on or about April 14, 2021; and/or b) pursuant to CPLR 3216 striking Defendant’s Demand to File Note of Issue, filed with this Court on March 19, 2021 [NYSCEF Doc. No. 195 because, on June 7, 2021 Defendant notified the undersigned that on May 19, 2021 Defendant 1 FILED: KINGS COUNTY CLERK 06/14/2021 10:56 AM INDEX NO. 510798/2018 NYSCEF DOC. NO. 262 RECEIVED NYSCEF: 06/14/2021 served a subpoena on Hull & Co., Inc. returnable after the note of issue deadline set by this Court; and/or c) pursuant to CPLR 2204 and/or CPLR 3216 and/or 22 NYCRR § 202.21(d), extending Atlantic Casualty Insurance Company’s (“Atlantic Casualty”) time to file a note of issue and certificate of readiness; and d) Pursuant to 22 NYCRR § 130-1.2 awarding Atlantic Casualty the costs associated with having to make this motion and imposing sanctions upon Defendant for its frivolous conduct in (i) serving a subpoena returnable after the note of issue deadline; (ii) refusing to speak with the undersigned to address their position with respect to the impact of Defendant’s pending subpoena on Atlantic Casualty’s ability to file the note of issue and/or whether the note of issue deadline should be extended; and (iii) abruptly hanging up on and refusing to speak with the undersigned to address this issue; and e) Pursuant to CPLR 3025 seeking to amend the ad damnum clause in the Complaint in light of documents received by the undersigned on June 9, 2021; and b) Granting Atlantic Casualty such other, further and different relief to plaintiff as this court deems just, equitable and proper; and it is further ORDERED that the deadline for Atlantic Casualty to file and serve a note of issue in this action, in particular any deadline pursuant to Defendant’s Demand to File Note of Issue as well as any other such deadline, to the extent necessary, be stayed and/or extended pending the hearing and determination of this motion; and it is further ORDERED that service of a copy of this Order to Show Cause, and the papers upon which it is based, upon Defendant Eastern Fruit & Vegetables Inc., through its counsel, by filing a copy 2 FILED: KINGS COUNTY CLERK 06/14/2021 10:56 AM INDEX NO. 510798/2018 NYSCEF DOC. NO. 262 RECEIVED NYSCEF: 06/14/2021 of this Order to Show Cause with Notice of Entry on the docket in NYSCEF. Such service shall be deemed timely if the Order to Show Cause with Notice of Entry is filed on or before June ___, 2021. Any opposition to this Order to Show Cause shall be filed on NYSCEF on or before _______________, 2021. Any reply to such opposition shall be filed on NYSCEF on or before ________________, 2021. E N T E R: Hon. 3 FILED: KINGS COUNTY CLERK 06/14/2021 10:56 AM INDEX NO. 510798/2018 NYSCEF DOC. NO. 262 RECEIVED NYSCEF: 06/14/2021 From: Debra Krebs To: blake@lblakemorris.com; info@lblakemorris.com Subject: RE: Atlantic Casualty v. Eastern Fruit Date: Friday, June 11, 2021 9:23:00 AM Attachments: OSC.pdf Please note that we have changed the filing date/time. An order to show cause requesting the relief requested in the attached will be filed on Monday, June 7, 2021 at 10:00 am or as soon thereafter as we are able to do so. Debbie Krebs Debra M. Krebs, Esq. Keidel, Weldon & Cunningham, LLP 925 Westchester Avenue Suite 400 White Plains, NY 10604 Tel: (914) 948-7000 (201) 490-7706 Fax: (914) 948-7010 dkrebs@kwcllp.com Confidentiality: The information contained in this e-mail message is intended only for the use of the individual or entity named above and is privileged and confidential. Any dissemination, distribution, or copy of this communication other than to the individual or entity named above is strictly prohibited. If you have received this communication in error, please notify us immediately by telephone. From: Debra Krebs Sent: Thursday, June 10, 2021 4:45 PM To: blake@lblakemorris.com; info@lblakemorris.com Subject: RE: Atlantic Casualty v. Eastern Fruit It appears there was a clerical error in the prior notice. Please see attached. The request for temporary relief is unchanged. Please be advised that we intend to file the order to show cause on June 11, 2021 at 10:00 am or as soon thereafter as we are able to do so. Debbie Krebs Debra M. Krebs, Esq. Keidel, Weldon & Cunningham, LLP 925 Westchester Avenue Suite 400 White Plains, NY 10604 Tel: (914) 948-7000 (201) 490-7706 Fax: (914) 948-7010 dkrebs@kwcllp.com FILED: KINGS COUNTY CLERK 06/14/2021 10:56 AM INDEX NO. 510798/2018 NYSCEF DOC. NO. 262 RECEIVED NYSCEF: 06/14/2021 Confidentiality: The information contained in this e-mail message is intended only for the use of the individual or entity named above and is privileged and confidential. Any dissemination, distribution, or copy of this communication other than to the individual or entity named above is strictly prohibited. If you have received this communication in error, please notify us immediately by telephone. From: Debra Krebs Sent: Thursday, June 10, 2021 3:49 PM To: blake@lblakemorris.com; info@lblakemorris.com Subject: Atlantic Casualty v. Eastern Fruit Please be advised that, since you have hung up on me and refused to address your position regarding your pending subpoena on the note of issue we need to file in this matter and/or whether an extension should be obtained, we are being forced to file the attached order to show cause and to request the temporary relief being sought therein. We intend to file the order to show cause on June 11, 2021 at 10:00 am or as soon thereafter as we are able to do so. Debbie Krebs Debra M. Krebs, Esq. Keidel, Weldon & Cunningham, LLP 925 Westchester Avenue Suite 400 White Plains, NY 10604 Tel: (914) 948-7000 (201) 490-7706 Fax: (914) 948-7010 dkrebs@kwcllp.com Confidentiality: The information contained in this e-mail message is intended only for the use of the individual or entity named above and is privileged and confidential. Any dissemination, distribution, or copy of this communication other than to the individual or entity named above is strictly prohibited. If you have received this communication in error, please notify us immediately by telephone. FILED: KINGS COUNTY CLERK 06/14/2021 10:56 AM INDEX NO. 510798/2018 NYSCEF DOC. NO. 262 RECEIVED NYSCEF: 06/14/2021 At IAS Part of the Supreme Court of the State of New York, held in and for the County of Kings at the Courthouse thereof located at 360 Adams Street, Brooklyn, New York on , 2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ATLANTIC CASUALTY INSURANCE Index No.: 510798/2018 COMPANY, Plaintiff, ORDER TO SHOW CAUSE v. EASTERN FRUIT & VEGETABLES INC. Defendant. Upon reading and filing the annexed affirmations of Debra M. Krebs, Esq., dated June __, 2021 with exhibits, and the accompanying memorandum of law, and upon all the prior pleadings and proceedings heretofore had herein; LET DEFENDANT EASTERN FRUIT & VEGETABLES INC. show cause before the Supreme Court of Kings County, IAS Part , Room , at the courthouse located at 360 Adams Street, Brooklyn, New York on , 2021, at 9:30 a.m. or as soon thereafter as counsel can be heard, why an order should not be made and entered, a) pursuant to CPLR 2304 to quash the subpoena which Defendant served upon Hull & Co., Inc. (“Hull”) on the basis that it is identical to a subpoena previously served upon Hull and to which Hull responded on or about April 14, 2021; and/or b) pursuant to CPLR 3216 striking Defendant’s Demand to File Note of Issue, filed with this Court on March 19, 2021 [NYSCEF Doc. No. 195 because, on June 7, 2021 Defendant notified the undersigned that on May 19, 2021 Defendant 1 FILED: KINGS COUNTY CLERK 06/14/2021 10:56 AM INDEX NO. 510798/2018 NYSCEF DOC. NO. 262 RECEIVED NYSCEF: 06/14/2021 served a subpoena on Hull & Co., Inc. returnable after the note of issue deadline set by this Court; and/or c) pursuant to CPLR 2204 and/or CPLR 3216 and/or 22 NYCRR § 202.21(d), extending Atlantic Casualty Insurance Company’s (“Atlantic Casualty”) time to file a note of issue and certificate of readiness; and d) Pursuant to 22 NYCRR § 130-1.2 awarding Atlantic Casualty the costs associated with having to make this motion and imposing sanctions upon Defendant for its frivolous conduct in (i) serving a subpoena returnable after the note of issue deadline; (ii) refusing to speak with the undersigned to address their position with respect to the impact of Defendant’s pending subpoena on Atlantic Casualty’s ability to file the note of issue and/or whether the note of issue deadline should be extended; and (iii) abruptly hanging up on and refusing to speak with the undersigned to address this issue; and e) Pursuant to CPLR 3025 seeking to amend the ad damnum clause in the Complaint in light of documents received by the undersigned on June 9, 2021; and b) Granting Atlantic Casualty such other, further and different relief to plaintiff as this court deems just, equitable and proper; and it is further ORDERED that the deadline for Atlantic Casualty to file and serve a note of issue in this action, in particular any deadline pursuant to Defendant’s Demand to File Note of Issue as well as any other such deadline, to the extent necessary, be stayed and/or extended pending the hearing and determination of this motion; and it is further ORDERED that service of a copy of this Order to Show Cause, and the papers upon which it is based, upon Defendant Eastern Fruit & Vegetables Inc., through its counsel, by filing a copy 2 FILED: KINGS COUNTY CLERK 06/14/2021 10:56 AM INDEX NO. 510798/2018 NYSCEF DOC. NO. 262 RECEIVED NYSCEF: 06/14/2021 of this Order to Show Cause with Notice of Entry on the docket in NYSCEF. Such service shall be deemed timely if the Order to Show Cause with Notice of Entry is filed on or before June ___, 2021. Any opposition to this Order to Show Cause shall be filed on NYSCEF on or before _______________, 2021. Any reply to such opposition shall be filed on NYSCEF on or before ________________, 2021. E N T E R: Hon. 3