On February 02, 2017 a
Exhibit,Appendix
was filed
involving a dispute between
Creative Kids Childcare Ltd.,
and
Csfb 2007-C4 Lakeview Plaza Shopping Center, Llc,
for Comm-Contract
in the District Court of Putnam County.
Preview
FILED: PUTNAM COUNTY CLERK 05/26/2017 01:08 PM INDEX NO. 500061/2017
NYSCEF DOC. NO. 124 RECEIVED NYSCEF: 05/26/2017
Exhibit 7
FILED: PUTNAM COUNTY CLERK 05/26/2017 01:08 PM INDEX NO. 500061/2017
NYSCEF DOC. NO. 124 RECEIVED NYSCEF: 05/26/2017
From: Slama, Mark [mailto:mslama@windelsmarx.com]
Sent: Tuesday, May 16, 2017 1:22 PM
To: Goodhouse, Brendan ; Corrigan, Daniel F. ;
jborkowski@kblaw.com
Cc: Brooks, Jordan M. ; Grauer, Joshua ; 'Rodriguez, Jorge'
Subject: RE: Creative Kids v. CSFB 2007-C4 Lakeview Plaza Shopping Center
I spoke with my client earlier. For reasons unrelated to your motion and based upon information and documents Jordan
provided to us recently, we are going to withdraw the prior notice we sent to your client and will not commence any
eviction action in June 2017. The foregoing is without prejudice to my client or its rights and remedies in the pending
litigation or in any future litigation between the parties. Nothing contained herein shall be construed to create rights
which do not otherwise exist.
You may consider this email as obviating the need to move for relief at this time.
Please confirm receipt of this email.
From: Goodhouse, Brendan [mailto:BGoodhouse@CUDDYFEDER.COM]
Sent: Tuesday, May 16, 2017 9:58 AM
To: Slama, Mark; Corrigan, Daniel F.; jborkowski@kblaw.com
Cc: Brooks, Jordan M.; Grauer, Joshua
Subject: Creative Kids v. CSFB 2007-C4 Lakeview Plaza Shopping Center
Counselors:
You are notified that tomorrow at 9:30 am we will be seeking a temporary restraining order in the above
referenced action restraining Defendant from commencing a summary holdover proceeding or taking any other
action in furtherance of the Eviction Notice, dated April 7.
If you would be willing to stipulate to Defendant holding the Eviction Notice in abeyance pending a decision on
our preliminary injunction motion then we can avoid the trip to court tomorrow and we will simply submit
papers via notice of motion with a mutually agreed upon briefing schedule and return date.
Please let us know if you would agree to such a stipulation or if we should all plan for court tomorrow.
Best
Brendan
Brendan M. Goodhouse, Esq.
Associate
1
FILED: PUTNAM COUNTY CLERK 05/26/2017 01:08 PM INDEX NO. 500061/2017
NYSCEF DOC. NO. 124 RECEIVED NYSCEF: 05/26/2017
Cuddy & Feder LLP
445 Hamilton Avenue, 14th Floor
White Plains, New York 10601
T 914 761 1300 | F 914 761 5372
BGoodhouse@cuddyfeder.com
cuddyfeder.com
------------------------------------------------------------------------------------
NOTE: The information in this e-mail message and any attachments thereto have been sent by an attorney
or his/her agent, and is or are intended to be confidential and for the use of only the individual or entity
named above. The information may be protected by attorney/client privilege, work product immunity or other
legal rules. If the reader of this message and any attachments thereto is not the intended recipient, you are
notified that retention, dissemination, distribution or copying of this e-mail message and any attachments is
strictly prohibited. Although this e-mail message (and any attachments) is believed to be free of any virus or
other defect that might affect any computer system into which it is received and opened, the intended
recipient is responsible to ensure that it is virus free. The sender and Cuddy & Feder LLP shall not have any
responsibility for any loss occasioned in any manner by the receipt and use of this e-mail message and any
attachments.
Pursuant to Treasury Regulations, any U.S. federal tax advice contained in this communication, unless
otherwise stated, is not intended and cannot be used for the purpose of avoiding tax-related penalties.
------------------------------------------------------------------------------------
2
Document Filed Date
May 26, 2017
Case Filing Date
February 02, 2017
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED: PUTNAM COUNTY CLERK 05/26/2017 01:08 PM INDEX NO. 500061/2017 NYSCEF DOC. NO. 124 RECEIVED NYSCEF: 05/26/2017 Exhibit 7 FILED: PUTNAM COUNTY CLERK 05/26/2017 01:08 PM INDEX NO. 500061/2017 NYSCEF DOC. NO. 124 RECEIVED NYSCEF: 05/26/2017 From: Slama, Mark [mailto:mslama@windelsmarx.com] Sent: Tuesday, May 16, 2017 1:22 PM To: Goodhouse, Brendan ; Corrigan, Daniel F. ; jborkowski@kblaw.com Cc: Brooks, Jordan M. ; Grauer, Joshua ; 'Rodriguez, Jorge' Subject: RE: Creative Kids v. CSFB 2007-C4 Lakeview Plaza Shopping Center I spoke with my client earlier. For reasons unrelated to your motion and based upon information and documents Jordan provided to us recently, we are going to withdraw the prior notice we sent to your client and will not commence any eviction action in June 2017. The foregoing is without prejudice to my client or its rights and remedies in the pending litigation or in any future litigation between the parties. Nothing contained herein shall be construed to create rights which do not otherwise exist. You may consider this email as obviating the need to move for relief at this time. Please confirm receipt of this email. From: Goodhouse, Brendan [mailto:BGoodhouse@CUDDYFEDER.COM] Sent: Tuesday, May 16, 2017 9:58 AM To: Slama, Mark; Corrigan, Daniel F.; jborkowski@kblaw.com Cc: Brooks, Jordan M.; Grauer, Joshua Subject: Creative Kids v. CSFB 2007-C4 Lakeview Plaza Shopping Center Counselors: You are notified that tomorrow at 9:30 am we will be seeking a temporary restraining order in the above referenced action restraining Defendant from commencing a summary holdover proceeding or taking any other action in furtherance of the Eviction Notice, dated April 7. If you would be willing to stipulate to Defendant holding the Eviction Notice in abeyance pending a decision on our preliminary injunction motion then we can avoid the trip to court tomorrow and we will simply submit papers via notice of motion with a mutually agreed upon briefing schedule and return date. Please let us know if you would agree to such a stipulation or if we should all plan for court tomorrow. Best Brendan Brendan M. Goodhouse, Esq. Associate 1 FILED: PUTNAM COUNTY CLERK 05/26/2017 01:08 PM INDEX NO. 500061/2017 NYSCEF DOC. NO. 124 RECEIVED NYSCEF: 05/26/2017 Cuddy & Feder LLP 445 Hamilton Avenue, 14th Floor White Plains, New York 10601 T 914 761 1300 | F 914 761 5372 BGoodhouse@cuddyfeder.com cuddyfeder.com ------------------------------------------------------------------------------------ NOTE: The information in this e-mail message and any attachments thereto have been sent by an attorney or his/her agent, and is or are intended to be confidential and for the use of only the individual or entity named above. The information may be protected by attorney/client privilege, work product immunity or other legal rules. If the reader of this message and any attachments thereto is not the intended recipient, you are notified that retention, dissemination, distribution or copying of this e-mail message and any attachments is strictly prohibited. Although this e-mail message (and any attachments) is believed to be free of any virus or other defect that might affect any computer system into which it is received and opened, the intended recipient is responsible to ensure that it is virus free. The sender and Cuddy & Feder LLP shall not have any responsibility for any loss occasioned in any manner by the receipt and use of this e-mail message and any attachments. Pursuant to Treasury Regulations, any U.S. federal tax advice contained in this communication, unless otherwise stated, is not intended and cannot be used for the purpose of avoiding tax-related penalties. ------------------------------------------------------------------------------------ 2