Letter,Correspondence: Shaul Kopelowitz v. Toby Moskowitz, Michael A/K/A Yechiel Lechtenstein

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                                LAW OFFICE OF
                                                        JEFFREY FLEISCHMANN, P.C.
                                                              150 Broadway, Suite 900
                                                            New York, New York 10038


                  JEFFREY FLEISCHMANN                                                     Telephone: (646) 657-9623
                                                                                          Facsimile: (646) 351-0694
                  _____________________________________________________________________________________________

                                                                                             January 29, 2021
                  Via E-File
                  Ex-Parte/Part 72
                  Supreme Court of the State of New York
                  County of Kings
                  360 Adams Street, Room 29
                  Brooklyn, New York 11201

                            Re:     Shaul Kopelowitz v. Toby Moskowitz, et al. (Index No. 527036/2019)

                  Dear Sir or Madam:

                           This firm represents the plaintiff in the above-referenced matter.             At approximately 12:03
                  p.m. this afternoon, a letter was filed and emailed to me by Israel Goldberg, Esq., counsel for
                  defendants Toby Moskowitz and Michael Lichtenstein in the above-referenced matter.                       The letter
                  from Mr. Goldberg informs me of his office’s intent to submit to the Court at 3:45 p.m. today an
                  order to show cause (“OSC”) seeking a stay of enforcement of this Court’s judgment, which was
                  entered on November 5, 2020 in favor of plaintiff and against defendants.

                           Respectfully, the order to show cause should be rejected and should not even be delivered
                  to the assigned judge because the notice provided is insufficient and, therefore, non-compliant with
                  defendants’ obligations under the CPLR and applicable local rules.                We assume that defendant’s
                  counsel selected late Friday afternoon as the time to file the OSC because he knows that both I and
                  my client are religiously observant and, therefore, likely would not be available with sundown
                  approaching to review the papers or appear on the matter.              He would be correct in that assumption
                  as I am not available to appear this afternoon, either by phone or by remote online communication.

                           To the extent that the Court is inclined to entertain the OSC, I am available at the Court’s
                  convenience any time next Monday or Tuesday.

                           Please contact me with any questions.          Thank you.

                                                                                          Respectfully submitted,

                                                                                          ______________________
                                                                                             Jeffrey Fleischmann
                  cc: All counsel (by NYSCEF)