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  • Cherry Hill Gourmet, Inc. v. Lundy'S Management Corp. Real Property - Other (Yellowstone Injunction) document preview
  • Cherry Hill Gourmet, Inc. v. Lundy'S Management Corp. Real Property - Other (Yellowstone Injunction) document preview
						
                                

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FILED: KINGS COUNTY CLERK 12/02/2020 01:27 PM INDEX NO. 510844/2016 NYSCEF DOC. NO. 663 LAW OFFI CES RECEIVED NYSCEF: 12/02/2020 OF HAGAN, COURY & ASSOCIATES A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATION AND PROFESSIONAL LIMITED LIABILITY COMPANY 908 FOURTH AVENUE BROOKLYN, NEW YORK 11232 (7 1 8) 788-505 2 SAMUEL L. HAGA N* *** WILLIAM J. COURY** CHRISTINA HAGAN OF COUNSEL JONATHAN A. FUCHS**** PAUL GOLDEN *PROFESSIONAL LIMITED LIABILITY COMPANY **PROFESSIONAL CORPORATION ***ADMITTED TO NEW YORK AND FLORIDA BARS ****ADMITTED TO NEW YORK BAR, SOLICITOR, ENGLAND & WALES December 2, 2020 Via Email (dpepper@nycourts.gov) Via Email (drodrig3@nycourts.gov) Via NYSCEF Hon. Larry Martin 360 Adams Street Brooklyn, NY 11201 Re: Cherry Hill Gourmet, Inc. - v. - Lundy's Management Corp. Index No: 510844/2016 Return date: 12/9/2020 Motion Sequence #11, #12, and #13. Dear Hon. Martin: This firm represents the third-party defendant Sheepshead Restaurant Associates Inc. in the above referenced action, and this is a request for virtual oral argument of the three pending motions on December 9, 2020. I believe oral arguments will clarify the crucial underlying issues, and will be beneficial to the court. My client is the owner and overlandlord of the subject premises. Lundy’s Management Corp. is the triple-net tenant, and Cherry Hill Gourmet, Inc. is a subtenant. A central issue in the motions is that months of Cherry Hill Gourmet Inc.’s subrent are now being held in escrow, and how they should be distributed. My client has not received any rental income since March, and needs those funds to pay its mortgage, real estate taxes, and water bills. Thank you in advance for your consideration. Respectfully yours, William J. Coury 16/53 /courtletter.v6 CC Counsel for Lundy’s Management Corp., and Cherry Hill Gourmet, Inc, via e mail. 1