On June 11, 2021 a
Letter,Correspondence
was filed
involving a dispute between
Nicholas Dassler,
and
Daniel B. Kremen,
Golden Hawk Llc,
for Torts - Motor Vehicle
in the District Court of Suffolk County.
Preview
SMITH MAZURE,P.C.
ATTO RNE YS AT L AW
Long Island Office: New Jersey Office:
200 Old Country Road, Suite 590 39 Broadway, 29th Floor 92 East Main Street, Suite 402
Mineola, New York 11501 New York, New York 10006-3053 Somerville, New Jersey 08876
(516) 414-7400 (212) 964-7400 (908) 393-7300
(516) 294-7325 Fax Fax (212) 374-1935 Fax (908) 231-1030
Writer’s Direct Dial: (212) 485-8768 Please Respond to:
jhosty@smithmazure.com Long Island:
February 23, 2023
VIA ECF
The Honorable Gloria Goldstein
Appellate Division, Second Department
45 Monroe Place
Brooklyn, NY 11201-2601
Re: Nicholas Dassler v. Daniel B. Kremen and Golden Hawk LLC.
Docket No. : 2022-04281
D/L : 12/8/2020
Our File : NIC-00913
Dear Honorable Goldstein:
Our office represents Defendants-Appellants Daniel B. Kremen and Golden Hawk LLC
in the above referenced matter. Please accept this letter application request pursuant to
22NYCRR §670.8(d) for an extension of time to perfect the defendants-appellants’ Appeal for
which a Notice of Appeal was served and filed on June 1, 2022. Defendants-Appellants
previously were granted a sixty day extension of time to appeal that expired on February 1, 2023
and a further thirty day extension that expires on March 1, 2023. Defendants-Appellants are
requesting a further sixty day extension of time due to plaintiff’s counsel filing an Order to Show
Cause to be relieved as counsel, which was returnable on February 7, 2023 and no decision has
been rendered. It is anticipated that the case will be stayed to allow plaintiff time to retain new
counsel.
This is an appeal from the order dated April 29, 2022 and entered in this action in the
office of the clerk of Suffolk County on May 2, 2022 granting plaintiff’s motion for summary
judgment on liability and for such other errors which may become apparent upon review of this
record on appeal.
The Honorable Gloria Goldstein, J.S.C.
Page 2
February 23, 2023
An extension of time is requested to allow time for plaintiff to retain new counsel and for
independent medical examinations of plaintiff to be conducted as it may impact settlement. As
you are aware, the last CAMP Conference was adjourned until January 30, 2023 to allow time
for same. It was thereafter cancelled due to the Order to Show Cause to be relieved as counsel.
Since then, plaintiff’s outgoing counsel has cancelled the scheduled independent medical
examinations. These examinations will need to be rescheduled once plaintiff retains new
counsel. As such, we respectfully request this extension in order to preserve judicial time and
economy.
Thank you for your consideration in this matter. Do not hesitate to contact the
undersigned with any questions.
Respectfully yours,
SMITH MAZURE, P.C.
By:
JACLYN C. HOSTY
JCH/nmo
cc:
Rosenberg & Gluck, L.L.P.
1176 Portion Road
Holtsville, NY 11742
(631) 451-7900/(631) 451-7955 (F)
VIA ECF
266
Document Filed Date
February 23, 2023
Case Filing Date
June 11, 2021
Category
Torts - Motor Vehicle
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Preview
SMITH MAZURE,P.C. ATTO RNE YS AT L AW Long Island Office: New Jersey Office: 200 Old Country Road, Suite 590 39 Broadway, 29th Floor 92 East Main Street, Suite 402 Mineola, New York 11501 New York, New York 10006-3053 Somerville, New Jersey 08876 (516) 414-7400 (212) 964-7400 (908) 393-7300 (516) 294-7325 Fax Fax (212) 374-1935 Fax (908) 231-1030 Writer’s Direct Dial: (212) 485-8768 Please Respond to: jhosty@smithmazure.com Long Island: February 23, 2023 VIA ECF The Honorable Gloria Goldstein Appellate Division, Second Department 45 Monroe Place Brooklyn, NY 11201-2601 Re: Nicholas Dassler v. Daniel B. Kremen and Golden Hawk LLC. Docket No. : 2022-04281 D/L : 12/8/2020 Our File : NIC-00913 Dear Honorable Goldstein: Our office represents Defendants-Appellants Daniel B. Kremen and Golden Hawk LLC in the above referenced matter. Please accept this letter application request pursuant to 22NYCRR §670.8(d) for an extension of time to perfect the defendants-appellants’ Appeal for which a Notice of Appeal was served and filed on June 1, 2022. Defendants-Appellants previously were granted a sixty day extension of time to appeal that expired on February 1, 2023 and a further thirty day extension that expires on March 1, 2023. Defendants-Appellants are requesting a further sixty day extension of time due to plaintiff’s counsel filing an Order to Show Cause to be relieved as counsel, which was returnable on February 7, 2023 and no decision has been rendered. It is anticipated that the case will be stayed to allow plaintiff time to retain new counsel. This is an appeal from the order dated April 29, 2022 and entered in this action in the office of the clerk of Suffolk County on May 2, 2022 granting plaintiff’s motion for summary judgment on liability and for such other errors which may become apparent upon review of this record on appeal. The Honorable Gloria Goldstein, J.S.C. Page 2 February 23, 2023 An extension of time is requested to allow time for plaintiff to retain new counsel and for independent medical examinations of plaintiff to be conducted as it may impact settlement. As you are aware, the last CAMP Conference was adjourned until January 30, 2023 to allow time for same. It was thereafter cancelled due to the Order to Show Cause to be relieved as counsel. Since then, plaintiff’s outgoing counsel has cancelled the scheduled independent medical examinations. These examinations will need to be rescheduled once plaintiff retains new counsel. As such, we respectfully request this extension in order to preserve judicial time and economy. Thank you for your consideration in this matter. Do not hesitate to contact the undersigned with any questions. Respectfully yours, SMITH MAZURE, P.C. By: JACLYN C. HOSTY JCH/nmo cc: Rosenberg & Gluck, L.L.P. 1176 Portion Road Holtsville, NY 11742 (631) 451-7900/(631) 451-7955 (F) VIA ECF 266