On August 17, 2021 a
Letter,Correspondence
was filed
involving a dispute between
Hello Living Developer Nostrand Llc,
Hello Nostrand Llc,
and
1580 Nostrand Mezz Llc,
Madison Realty Capital Lp,
for Commercial - Business Entity
in the District Court of Rockland County.
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FILED: ROCKLAND COUNTY CLERK 01/25/2023 04:58 PM INDEX NO. 034885/2021
NYSCEF DOC. NO. 162 RECEIVED NYSCEF: 01/25/2023
MorrisoflCohen..,n
31',5i:ii:i,,
gpollack@morrisoncohen.com
lanuary 24,2023
VIA NYSCEF AIID EMAIL
Hon. Paul I. Marx
Supreme Court of New York
County of Rockland
1 South Main Street
New City, New York 10956
bglafont@nycourts. gov, mhomenic@nycourts. gov, i lazzaro6an.vcouns. sov
Re: Hello Living Developer Nostrand LLC v. l5B0 Nostand Mezz LLC,
Rockland Cty. Sup. Ct. lndex No. 034885/2021
Your Honor:
My firm represents Defendant Nostrand Mezz Lender LLC. I am writing to
respectfully request a 30-day extension of time to move to dismiss the amended complaint. ihis
is Defendant's first request for an adjournment. plaintiff consents to the requested exiension.
Plaintiff Hello Living Developer Nostrand LLC filed its Amended complaint on
November30,2022 [NYSCEF No. 155]. At a conference on December 21, 2022, the court set a
briefing schedule for Defendant to move to dismiss the Amended complaint as follows: Motion
to Dismiss due February 6, 2023; Opposition due March 6, 2023; Reply due March 1.7, ZOZ3).
At this time, the parties are engaged in settlement discussions. To ficilitate those discussions,
Defendant seeks (and Plaintiff consents to) an extension of 30 days for Nostrand Mezz to
respond to the Amended Complaint.
, Defendant accordingly respectfully requests that this Court approve the following
efing schedule for the motion to dismiss the Amended Complaint:
Motion to Dismiss: March 8, 2023
Opposition: April7,2023
Reply: April 18,2023
-T\ L \\r\'. CnrrQ.....'a- 11 {,"-..d \
Respectfully submitted,
't\,-d*. /s/ Gayle Pollack
CC All
au o^I--L
counseI ofrecord via NYSCEF
i
909 Third Avenue, New York, NY l0022-4784 . p:212.735.8600 . ft|t2,73S.B708. www.morrisoncohen.com
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Document Filed Date
January 25, 2023
Case Filing Date
August 17, 2021
Category
Commercial - Business Entity
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FILED: ROCKLAND COUNTY CLERK 01/25/2023 04:58 PM INDEX NO. 034885/2021 NYSCEF DOC. NO. 162 RECEIVED NYSCEF: 01/25/2023 MorrisoflCohen..,n 31',5i:ii:i,, gpollack@morrisoncohen.com lanuary 24,2023 VIA NYSCEF AIID EMAIL Hon. Paul I. Marx Supreme Court of New York County of Rockland 1 South Main Street New City, New York 10956 bglafont@nycourts. gov, mhomenic@nycourts. gov, i lazzaro6an.vcouns. sov Re: Hello Living Developer Nostrand LLC v. l5B0 Nostand Mezz LLC, Rockland Cty. Sup. Ct. lndex No. 034885/2021 Your Honor: My firm represents Defendant Nostrand Mezz Lender LLC. I am writing to respectfully request a 30-day extension of time to move to dismiss the amended complaint. ihis is Defendant's first request for an adjournment. plaintiff consents to the requested exiension. Plaintiff Hello Living Developer Nostrand LLC filed its Amended complaint on November30,2022 [NYSCEF No. 155]. At a conference on December 21, 2022, the court set a briefing schedule for Defendant to move to dismiss the Amended complaint as follows: Motion to Dismiss due February 6, 2023; Opposition due March 6, 2023; Reply due March 1.7, ZOZ3). At this time, the parties are engaged in settlement discussions. To ficilitate those discussions, Defendant seeks (and Plaintiff consents to) an extension of 30 days for Nostrand Mezz to respond to the Amended Complaint. , Defendant accordingly respectfully requests that this Court approve the following efing schedule for the motion to dismiss the Amended Complaint: Motion to Dismiss: March 8, 2023 Opposition: April7,2023 Reply: April 18,2023 -T\ L \\r\'. CnrrQ.....'a- 11 {,"-..d \ Respectfully submitted, 't\,-d*. /s/ Gayle Pollack CC All au o^I--L counseI ofrecord via NYSCEF i 909 Third Avenue, New York, NY l0022-4784 . p:212.735.8600 . ft|t2,73S.B708. www.morrisoncohen.com 1 of 1