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  • Kenneth Miller v. David Strothers, Eric Bevard, Gretchen BevardReal Property - Other (Declaratory Judgment/Ease) document preview
  • Kenneth Miller v. David Strothers, Eric Bevard, Gretchen BevardReal Property - Other (Declaratory Judgment/Ease) document preview
						
                                

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Mitchell J. Katz Partner December 16, 2019 VIA ECF Hon. James P. McClusky, JSC Supreme Court Chambers Jefferson County Courthouse Watertown, NY 13601 Re: Miller v. Hunkele and Strothers Index No. EF2018-00001369 Motion Return Date 8/22/19 9:30 a.m. Dear Justice McClusky: My firm represents Mr. Hunkele. I write to report that Mr. Hunkele is in the process of selling the property that is part of the subject of this action. Title information has been shared with the buyer’s bank’s counsel and we anticipate that approval of the loan to complete the purchase is forthcoming. Assuming the sale closes, the buyer will succeed to the interests of Mr. Hunkele in the subject of this action. We are informed that the buyer has retained counsel who will appear in this action for the buyer who will be substituted as the new party in interest. For the foregoing reasons, we respectfully request that the Court accept this letter as a request to adjourn the telephone conference scheduled for December 18. We will update the Court and counsel, hopefully before the end of December, concerning the sale and substitution of a new party and new counsel for that party. Thank you for Your Honor’s consideration of this report and request. Respectfully submitted, /s/ Mitchell J. Katz Mitchell J. Katz MJK:ead cc: All Counsel via ECF