Request,Application: Exrp 14 Holdings Llc v. Ls-14 Ave Llc

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                                SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK

 EXRP 14 HOLDINGS LLC,
                                                           Index No. 652698/2022
                 Plaintiff,
                                                           Hon. Melissa A. Crane
         - against -
                                                           STIPULATION AND REQUEST
 LS-14 AVE LLC,
                                                           TO SO-ORDER
                 Defendant.


       WHEREAS, Defendant filed an Answer to the Complaint with Counterclaims on

January 20, 2023 (Dkt. 78) (the “Counterclaims”);

       WHEREAS, as discussed with the Court on January 26, 2023, Plaintiff intends to move

to dismiss the Counterclaims;

       WHEREAS, there have been no previous requests for extension of time in connection

with this matter;

       IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned

attorneys for the parties, as follows:

       1. Plaintiff will file its motion to dismiss the Counterclaims on or before March 3, 2023;

       2. Defendant will file its opposition to Plaintiff’s motion on or before March 31, 2023;

       3. Plaintiff will file its reply on or before April 28, 2023.

       IT IS FURTHER STIPULATED AND AGREED that this Stipulation is without

prejudice to the Parties’ rights and defenses, all of which are expressly reserved.

       IT IS FURTHER STIPULATED AND AGREED that this Stipulation may be

executed in counterparts and facsimile signatures shall constitute originals.
Dated:      February 9, 2023

 CYRULNIK FATTARUSO LLP                   KASOWITZ BENSON TORRES LLP


 By:     /s/ Jason Cyrulnik               By:    /s/ Jennifer McDougall
          Jason Cyrulnik                        Jennifer McDougall
 55 Broadway, Third Floor                 1633 Broadway
 New York, New York 10006                 New York, New York 10019
 (646) 844-2466                           (212) 506-1700

 Counsel for Plaintiff                    Counsel for Defendant




SO ORDERED:



                               , J.S.C.




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