Letter,Correspondence: Rashbi Management, Inc. v. Diamond Hill Nursing And Rehabilitation Center Nka Collar City Nursing And Rehabilitation Center, Oriska Insurance Company

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                                Cullen and Dykman LLP
                                                                                        80 State Street, Suite 900
                                                                                       Albany, New York 12207
                                                                                T: 518.788.9406 | F: 518.689.9519


 CHRISTOPHER E. BUCKEY
 PARTNER
 DIRECT: (518) 788-9406
 CBUCKEY@CULLENLLP.COM




                                                              March 7, 2023

VIA NYSCEF
Hon. Peter A. Lynch
Supreme Court, Albany County Albany
County Courthouse
16 Eagle Street
Albany, NY 12207

           Re:    Rashbi Management, Inc. v. Avalon Gardens Rehabilitation & Health
                  Care Center, LLC dba Brookside Multicare Nursing Center, et. al.
                  Index No. 907154- 22 (Sup Ct, Albany Cty)

                  Rashbi Management, Inc. v. Baypark Center for Nursing and
                  Rehabilitation, LLC nka Pinnacle Multicare Nursing & Rehabilitation, et. al.
                  Index No. 907880-22 (Sup Ct, Albany Cty)

                  Rashbi Management, Inc. v. Niskayuna Operating Co LLC dba Pathways
                  Nursing & Rehabilitation Center, et. al.
                  Index No. 907946-22 (Sup Ct, Albany Cty)

                  Rashbi Management, Inc. v. Highgate LTC Management LLC dba
                  Northwoods Rehabilitation & Extended Care Facility at Rosewood, et. al.
                  Index No. 908060-22 (Sup Ct, Albany Cty)

                  Rashbi Management, Inc. v. Garden Care Center, Inc., et. al.
                  Index No. 908062-22 (Sup Ct, Albany Cty)

                  Rashbi Management, Inc. v. Diamond Hill Nursing and Rehabilitation
                  Center NKA Collar City Nursing and Rehabilitation Center, et. al.
                  Index No. 908063-22 (Sup Ct, Albany Cty)

                  Rashbi Management, Inc. v. Eastchester Rehabilitation & Health Care Center,
                  LLC, et. al.
                  Index No. 908065-22 (Sup Ct, Albany Cty)

                  Rashbi Management, Inc. v. Golden Gate Rehabilitation & Health Care Center,
                  LLC, et. al.
                  Index No. 908120-22 (Sup Ct, Albany Cty)
                                          FO U N D E D 1850
                               NEW YORK    NEW JERSEY   WASHINGTON DC
                                                                                    March 7, 2023
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Rashbi Management, Inc. v. Pinegrove Manor IL LLC dba Grace Plaza Nursing
and Rehabilitation Center, et. al.
Index No. 908229-22 (Sup Ct, Albany Cty)

Rashbi Management, Inc. v. Park Avenue Operating Company, LLC dba Park
Avenue Extended Care Facility, et. al.
Index No. 908231-22 (Sup Ct, Albany Cty)

Rashbi Management, Inc. v. Little Neck Nursing Home LLC, Little Neck Care
Center, LLC, et. al.
Index No. 908233-22 (Sup Ct, Albany Cty)

Rashbi Management, Inc. v. New Surfside Nursing Home, LLC, et. al.
Index No. 908234-22 (Sup Ct, Albany Cty)

Rashbi Management, Inc. v. North Sea Associates, LLC dba The Hamptons Center for
Rehabilitation and Nursing, et. al.
Index No. 908235-22 (Sup Ct, Albany Cty)

Rashbi Management, Inc. v. Townhouse Operating Company, LLC dba Townhouse
Center for Rehabilitation & Nursing, et. al.
Index No. 908305-22 (Sup Ct, Albany Cty)

Rashbi Management, Inc. v. Bayview Manor LLC dba South Point Plaza Nursing and
Rehabilitation Center, et. al.
Index No. 908307-22 (Sup Ct, Albany Cty)

Rashbi Management, Inc. v. Parkview Care and Rehabilitation Center, Inc., et. al.
Index No. 908313-22 (Sup Ct, Albany Cty)

Rashbi Management, Inc. v. Willoughby Rehabilitation & Health Care Center LLC
dba Spring Creek Rehabilitation & Nursing Care Center, et. al.
Index No. 908315-22 (Sup Ct, Albany Cty)

Rashbi Management, Inc. v. Shorefront Operating LLC dba Seagate Rehabilitation &
Health Care Center, et. al.
Index No. 908320-22 (Sup Ct, Albany Cty)

Rashbi Management, Inc. v. Cold Spring Acquisition, LLC, et. al.
Index No. 908321-22 (Sup Ct, Albany Cty)

Rashbi Management, Inc. v. Throgs Neck Operating Company, LLC dba Throgs Neck
Extended Care Facility, et. al.
Index No. 908324-22 (Sup Ct, Albany Cty)
                                                                                               March 7, 2023
                                                                                                      Page 3




Dear Justice Lynch:

       This firm represents the Defendants in each of the above-referenced actions.

        The summary judgment motions of Plaintiff Rashbi Management, Inc. (“Plaintiff’”) in each
of these actions currently are returnable on April 12, 2023.

        In light of this Court’s February 28, 2023 Decision and Order in Rashbi Management, Inc.
v. Brookhaven Rehabilitation & Health Care Center, LLC, Oriska Insurance Company, Index No.:
909306-21 (Sup Ct, Albany Cty), Plaintiff’s counsel has agreed to adjourn the return dates of these
pending motions to May 3, 2023. Based upon this adjournment, Defendants’ opposition papers
will be due on or before April 5, 2023.

       If the Court approves of the foregoing adjournment, please “So-Order” this letter and file
it on NYSCEF in each of the respective actions at the Court’s convenience.

                                                            Respectfully,


                                                            Christopher E. Buckey

cc:    All counsel of record via NYSCEF


SO ORDERED:

___________________________
Hon. Peter A. Lynch