Preview
FILED: KINGS COUNTY CLERK 03/15/2023 02:07 PM INDEX NO. 507980/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/15/2023
EXHIBIT A
FILED: KINGS COUNTY CLERK 03/15/2023 02:07 PM INDEX NO. 507980/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/15/2023
CLARK GULDIN
ATTORNEYS AT LAW
jurbano@clarkguldin.com
Reply to: MONTCLAIR
Direct Dial: (973) 314-1907
February 7, 2023
VIA FEDEX AND PERSONAL SERVICE
Andy Culuris Culuris
Andy
President President
HIG Services Inc. HIG Services Inc.
25 Field Street 25 Arista Dr.
West Babylon, NY 11704 Dix Hills, NY 11746
Re: Notice to Commence Action or Show Cause Pursuant to Lien Law § 59;
80 Pine Street, New York NY 10005;
422 Fulton Street, Brooklyn NY 11201
Dear Mr. Culuris,
This firm represents JRM Construction Management ("JRM"). Enclosed please find four
(4) Notices to Commence Action or Show Cause Pursuant to Lien Law
§ 59 on or before March 13, 2023.
Sincerely,
Jeuracwie
Janesa Urbano, Esq.
Enclosures
20 Church Suite 07042 " T: 973.707.5346 F: 973.707.7631
Street, 15, Montclair, NJ
- 1} 242 West 36th Street,12th New NY 10018 " T: 646.720.0433
{00115074 Floor, York,
www.clarkguldin.com
FILED: KINGS COUNTY CLERK 03/15/2023 02:07 PM INDEX NO. 507980/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/15/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
Index No.: ______/____
In the Matter of the Application of
JRM CONSTRUCTION MANAGEMENT LLC, NOTICE TO COMMENCE
Requiring HIG SERVICES, INC., Lienor, to Enforce ACTION OR SHOW
Its Lien or Show Cause Why the Notice of Lien CAUSE PURSUANT TO
Should Not Be Vacated and Cancelled of Record as LIEN LAW § 59
Prescribed by § 59 of the Lien Law.
PLEASE TAKE NOTICE that Pursuant to Section 59 of the Lien Law, you are hereby required to
commence an action on or before the 13th day of March, 2023, to enforce the lien filed by you in
the Office of the Clerk of Kings County, on December 20, 2022, in the sum of fifty thousand seven
hundred forty-two and 25/100 dollars ($50,742.25), against 422 Fulton Owner, L.L.C., as owner
in fee, and JRM Construction Management LLC, as contractor, and affecting premises located in
the City of Brooklyn, County of Kings, State of New York and described as follows: Block 156,
Lots 1202 and 1203, also known as Macy’s 2nd Floor at 422 Fulton Street, Brooklyn, New York
11201; or in the event of your failure to commence such action that you appear at an IAS Part of
this Court to be held at the courthouse thereof, located at 360 Adams Street, Brooklyn, New York
11201, on the 3rd day of April, 2023, at 9:30 a.m. or as soon thereafter as counsel can be heard,
and show cause why an order should not be made vacating and cancelling said Notice of Lien of
record.
Dated: New York, New York
February 7, 2023
CLARK GULDIN ATTORNEYS AT LAW
Attorneys for Applicant JRM Construction
Management LLC
Janesa Urbano
By: Janesa Urbano, Esq.
242 West 36th Street, 9th Floor
New York, NY 10018
&
20 Church Street, Suite 15
Montclair, NJ 07042
(973) 707-5346
{00114532 - 1}
FILED: KINGS COUNTY CLERK 03/15/2023 02:07 PM INDEX NO. 507980/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/15/2023
TO: Andy Culuris
President
HIG Services, Inc.
25 Field Street,
West Babylon, NY 11704
{00114532 - 1}
Preview
FILED: KINGS COUNTY CLERK 03/15/2023 02:07 PM INDEX NO. 507980/2023 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/15/2023 EXHIBIT A FILED: KINGS COUNTY CLERK 03/15/2023 02:07 PM INDEX NO. 507980/2023 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/15/2023 CLARK GULDIN ATTORNEYS AT LAW jurbano@clarkguldin.com Reply to: MONTCLAIR Direct Dial: (973) 314-1907 February 7, 2023 VIA FEDEX AND PERSONAL SERVICE Andy Culuris Culuris Andy President President HIG Services Inc. HIG Services Inc. 25 Field Street 25 Arista Dr. West Babylon, NY 11704 Dix Hills, NY 11746 Re: Notice to Commence Action or Show Cause Pursuant to Lien Law § 59; 80 Pine Street, New York NY 10005; 422 Fulton Street, Brooklyn NY 11201 Dear Mr. Culuris, This firm represents JRM Construction Management ("JRM"). Enclosed please find four (4) Notices to Commence Action or Show Cause Pursuant to Lien Law § 59 on or before March 13, 2023. Sincerely, Jeuracwie Janesa Urbano, Esq. Enclosures 20 Church Suite 07042 " T: 973.707.5346 F: 973.707.7631 Street, 15, Montclair, NJ - 1} 242 West 36th Street,12th New NY 10018 " T: 646.720.0433 {00115074 Floor, York, www.clarkguldin.com FILED: KINGS COUNTY CLERK 03/15/2023 02:07 PM INDEX NO. 507980/2023 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/15/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS Index No.: ______/____ In the Matter of the Application of JRM CONSTRUCTION MANAGEMENT LLC, NOTICE TO COMMENCE Requiring HIG SERVICES, INC., Lienor, to Enforce ACTION OR SHOW Its Lien or Show Cause Why the Notice of Lien CAUSE PURSUANT TO Should Not Be Vacated and Cancelled of Record as LIEN LAW § 59 Prescribed by § 59 of the Lien Law. PLEASE TAKE NOTICE that Pursuant to Section 59 of the Lien Law, you are hereby required to commence an action on or before the 13th day of March, 2023, to enforce the lien filed by you in the Office of the Clerk of Kings County, on December 20, 2022, in the sum of fifty thousand seven hundred forty-two and 25/100 dollars ($50,742.25), against 422 Fulton Owner, L.L.C., as owner in fee, and JRM Construction Management LLC, as contractor, and affecting premises located in the City of Brooklyn, County of Kings, State of New York and described as follows: Block 156, Lots 1202 and 1203, also known as Macy’s 2nd Floor at 422 Fulton Street, Brooklyn, New York 11201; or in the event of your failure to commence such action that you appear at an IAS Part of this Court to be held at the courthouse thereof, located at 360 Adams Street, Brooklyn, New York 11201, on the 3rd day of April, 2023, at 9:30 a.m. or as soon thereafter as counsel can be heard, and show cause why an order should not be made vacating and cancelling said Notice of Lien of record. Dated: New York, New York February 7, 2023 CLARK GULDIN ATTORNEYS AT LAW Attorneys for Applicant JRM Construction Management LLC Janesa Urbano By: Janesa Urbano, Esq. 242 West 36th Street, 9th Floor New York, NY 10018 & 20 Church Street, Suite 15 Montclair, NJ 07042 (973) 707-5346 {00114532 - 1} FILED: KINGS COUNTY CLERK 03/15/2023 02:07 PM INDEX NO. 507980/2023 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/15/2023 TO: Andy Culuris President HIG Services, Inc. 25 Field Street, West Babylon, NY 11704 {00114532 - 1}