On September 23, 2020 a
Letter,Correspondence
was filed
involving a dispute between
Esmelin Pena,
Leonela Pena,
and
Van Courtlandt Assets Llc,
for Other Matters - Contract - Other
in the District Court of Bronx County.
Preview
THOMAS J. HILLGARDNER, ESQ.
Attorney-at-Law
82-63 170lh Street
Jamaica, New York 11432
(718) 657-0606
tomhillgardner@gmall.com
October 31 , 2022
VIA NYSCEF and email to
BxSupCiv-IA6@nycourts.gov
Hon. Laura G. Douglas, J.S.C.
Supreme Court of the State of New York
Bronx County
851 Grand Concourse
Bronx, New York 10458
RE: Pena v. Van Courtlandt Assets, LLC
(Sup. Ct., Bronx Co., Index No. 30724/2020E)
Permission to File Overlength Brief
Dear Judge Douglas,
I am the attorney for the plaintiffs Esmelin Pena and Leonela Pena in the above
referenced action for rent overcharge and I write seeking permission to file an overlength
memorandum of law on a motion for summary judgment that I have prepared and intend to fi le. I
respectfully request leave to file a memorandum of law running 27 pages in length and
containing 8,847 words inclusive of footnotes.
The reason the brief is overlength is because defendants have asserted twelve affirmative
defenses and on plaintiffs motion for summary judgment plaintiff is required to address each of
them. Indeed, the portion of the memorandum of law that addresses the striking of the
affirmative defenses and the dismissal of defendant's counterclaim for attorney's fees comprises
16 of the 27 pages of the document. The section of the brief actually addressing the merits of the
motion for summary judgment on plaintiffs causes of action for rent overcharge runs a mere six
and one-half pages in length while addressing two discrete issues.
Accordingly, plaintiff asks this Court for permission to file an overlength brief on its
motion for summary judgment.
. Hillgardner, Esq.
cc: Micheli Perez, Esq.
Document Filed Date
October 31, 2022
Case Filing Date
September 23, 2020
Category
Other Matters - Contract - Other
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THOMAS J. HILLGARDNER, ESQ. Attorney-at-Law 82-63 170lh Street Jamaica, New York 11432 (718) 657-0606 tomhillgardner@gmall.com October 31 , 2022 VIA NYSCEF and email to BxSupCiv-IA6@nycourts.gov Hon. Laura G. Douglas, J.S.C. Supreme Court of the State of New York Bronx County 851 Grand Concourse Bronx, New York 10458 RE: Pena v. Van Courtlandt Assets, LLC (Sup. Ct., Bronx Co., Index No. 30724/2020E) Permission to File Overlength Brief Dear Judge Douglas, I am the attorney for the plaintiffs Esmelin Pena and Leonela Pena in the above referenced action for rent overcharge and I write seeking permission to file an overlength memorandum of law on a motion for summary judgment that I have prepared and intend to fi le. I respectfully request leave to file a memorandum of law running 27 pages in length and containing 8,847 words inclusive of footnotes. The reason the brief is overlength is because defendants have asserted twelve affirmative defenses and on plaintiffs motion for summary judgment plaintiff is required to address each of them. Indeed, the portion of the memorandum of law that addresses the striking of the affirmative defenses and the dismissal of defendant's counterclaim for attorney's fees comprises 16 of the 27 pages of the document. The section of the brief actually addressing the merits of the motion for summary judgment on plaintiffs causes of action for rent overcharge runs a mere six and one-half pages in length while addressing two discrete issues. Accordingly, plaintiff asks this Court for permission to file an overlength brief on its motion for summary judgment. . Hillgardner, Esq. cc: Micheli Perez, Esq.