Letter,Correspondence: Jardan 520 Llc v. Bvs Acquisition Co. Llc, M&T Bank, 86th Street Lender Llp

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                                June     17,    2022

                  Via    NYSCEF       &  E-Mail
                  Hon.     W.   Franc      Perry,       III,     J.S.C.
                  New    York     Supreme        Court
                  Part     23,    Room     543
                  60   Centre       Street
                  New    York,      New    York     10013
                  sfc-part23-clerk@nycourts.gov

                           Re:      Jardan       520    LLC    v.   BVS     Acquisition          Co.    LLC     et   al.,
                                    Index      No.    153512/2022
                                    Request       For     Adjournment          Of    Order     To    Show     Cause

                  Dear     Justice       Perry:

                           I   write      on   behalf       of   counsel        for    86th    Street      Lender       LLC(“86th
                  Street”)           and    Jardan       520    LLC       (“Jardan”)          in    the    above       matter      to
                  seek     the     following         extensions           and    adjournments,             as    set    forth      in
                  the    accompanying            stipulaton:

                       (i)      an    adjournment           of   the     hearing       date      for    the     order      to   show
                                cause      for    a   stay     of    proceedings           filed      by   86th    to    the    week
                                of   July     18,    2022   1,   or   as   the    Court      is   thereafter          available,
                                and




                  1   The   parties     request     a  hearing     date   the   week    of  July    18,   2022   as   Counsel     for
                  Jardan     is  scheduled      for   an   arbitration       the   week   of   July   5,   2022   and   I  am
                  scheduled      to   be  on   long   planned     vacation      the   week   of   July   11,   2022.
                  Hon.     W.   Franc      Perry,       III,     J.S.C.
                  June     17,    2022
                  Pg.    2

                       (ii)     an   extension         of   the    date     that     Jardan      has    to   file     a  response
                                to    the    order      to    show     cause      to    two    business         days     prior      to
                                the    new    hearing        date.

                             Through       the     order      to    show     cause,       86th    Street       is    seeking       an
                  order      from     the     Court      staying        the    instant        petition         in   favor      of    a
                  contempt        proceeding          in    a   Connecticut           Probate       Court.       Counsel        have
                  agreed       to   allow      the     Connecticut          hearing        to    proceed       first,       and    at
                  this     point      in   time,      the    Connecticut           hearing       has    been     adjourned         on
                  the    consent        of   all    parties        to   July     1,   2022.

                           For     these       reasons,         counsel        seeks       the     above       extension          and
                  adjournment.               Should       the    Court      wish     to   confer       with     counsel       about
                  potential         dates      for    the    hearing,        we    will     make     ourselves         available
                  to   the     Court     as    needed.

                                                                        Respectfully           submitted,


                                                                        /s/    Bradley        L.   Rice
                                                                        Bradley       L.    Rice

                  Cc:      All    Counsel        (via     NYSCEF      &   E-Mail)