Preview
FILED: NEW YORK COUNTY CLERK 07/25/2023 04:54 PM INDEX NO. 157429/2023
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 07/25/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
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In the Matter of the Application of
125 BROAD CHP, LLC,
Petitioner,
Index No.
For an Order Pursuant to Lien Law §37 Determining the
Amount of a Bond to Be Filed with the New York County
NOTICE OF
Clerk to Discharge Six Mechanic’s Liens Filed Against
PETITION
Real Property Known as 125 Broad Street, New York,
New York by FINE CRAFTSMAN GROUP, LLC or
Which may be Filed Regarding Performance Under a
Certain Contract with FINE CRAFTSMAN GROUP, LLC at
125 Broad Street, New York, New York, Where Certain Lots
Thereupon are Owned by SULLIVAN & CROMWELL, LLP,
125 ACQUISITION, LLC and THE AMERICAN CIVIL
LIBERTIES UNION FOUNDATION, INC., and Interested
Parties are THE 125 BROAD CONDOMINIUM, WELLS
FARGO BANK N.A. and HARCO NATIONAL
INSURANCE COMPANY,
Respondents.
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PLEASE TAKE NOTICE, that, upon the annexed Verified Petition of Jeremy Kalina,
Esq. of Kalina & Mattia, P.C., attorneys for Petitioner 125 Broad CHP, LLC, dated and verified
the 25th day of July, 2023, and the exhibits annexed thereto, the undersigned will move this Court,
at the Motion Support Part, Room 130, in the Supreme Courthouse located at 60 Centre Street,
New York, New York 10007, on the 28th day of August at 9:30 o’clock in the forenoon or as soon
thereafter as counsel can be heard, for an Order pursuant to Lien Law §37 determining and setting
the amount of a certain single lien discharge bond in the penal sum of $1,628,144.38, which
Petitioner 125 Broad CHP, LLC may file with the New York County Clerk, which shall: (A)
discharge six mechanic’s liens filed by Respondent Fine Craftsman Group, LLC against real
property at 125 Broad Street, New York, New York 10004; and (B) which bond shall substitute
for and replace the lien discharge bond previously filed by Petitioner 125 Broad CHP, LLC with
the New York County Clerk that discharged one of the six mechanic’s liens Respondent Fine
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FILED: NEW YORK COUNTY CLERK 07/25/2023 04:54 PM INDEX NO. 157429/2023
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 07/25/2023
Craftsman Group, LLC previously filed against real property at 125 Broad Street, New York, New
York 10004; and (3) for such other and further relief as this Court may deem just and proper.
PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR § 403 and CPLR § 2214,
that answering papers, if any, shall be served at least seven days before the aforesaid return date.
Petitioner designates New York County as the place of hearing or trial, as New York
County is the County where the property against which the Respondent Fine Craftsman Group,
LLC filed a total of six mechanic’s liens is located, which is the subject of this Petition.
Dated: Woodbury, New York
July 25, 2023 KALINA & MATTIA, P.C.
Attorneys for Petitioner
Jeremy Kalina
___________________________
By: Jeremy Kalina, Esq.
80 Crossways Park Drive, Suite 300
Woodbury, NY 11797
To: (516) 247-6445
Fine Craftsman Group, LLC
74-06 Metropolitan Avenue
Middle Village, NY 11379
Sullivan & Cromwell LLP
125 Broad Street
New York, NY 10004
125 Acquisition, LLC
125 Broad Street
New York, NY 10004
The American Civil Liberties Union Foundation, Inc.
125 Broad Street
New York, NY 10004
The 125 Broad Condominium
125 Broad Street
New York, New York 10004
Wells Fargo Bank N.A.
150 East 42nd Street, 35th Floor
New York, NY 10017
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FILED: NEW YORK COUNTY CLERK 07/25/2023 04:54 PM INDEX NO. 157429/2023
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 07/25/2023
Harco National Insurance Company
4200 Six Forks Road, Suite 1400
Raleigh, NC 27609
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FILED: NEW YORK COUNTY CLERK 07/25/2023 04:54 PM INDEX NO. 157429/2023
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 07/25/2023
Index No.
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
In the Matter of the Application of
125 BROAD CHP, LLC,
Petitioner,
For an Order Pursuant to Lien Law §37 Determining the
Amount of a Bond to Be Filed with the New York County
Clerk to Discharge Six Mechanic’s Liens Filed Against
Real Property Known as 125 Broad Street, New York,
New York by FINE CRAFTSMAN GROUP, LLC or
Which may be Filed Regarding Performance Under a
Certain Contract with FINE CRAFTSMAN GROUP, LLC at
125 Broad Street, New York, New York, Where Certain Lots
Thereupon are Owned by SULLIVAN & CROMWELL, LLP,
125 ACQUISITION, LLC and THE AMERICAN CIVIL
LIBERTIES UNION FOUNDATION, INC., and Interested
Parties are THE 125 BROAD CONDOMINIUM, WELLS
FARGO BANK N.A. and HARCO NATIONAL
INSURANCE COMPANY,
Respondents.
NOTICE OF PETITION
Signature (Rule 130-1.1-a Compliance)
Jeremy Kalina
KALINA & MATTIA, P.C.
Attorneys for Petitioner
80 Crossways Park Drive
Suite 300
Woodbury, NY 11797
(516) 247-6445
To
Attorney(s) for
Service of a copy of the within is hereby admitted.
Dated,
Attorney(s) for .........................................................
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Preview
FILED: NEW YORK COUNTY CLERK 07/25/2023 04:54 PM INDEX NO. 157429/2023 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 07/25/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ----------------------------------------------------------------------------X In the Matter of the Application of 125 BROAD CHP, LLC, Petitioner, Index No. For an Order Pursuant to Lien Law §37 Determining the Amount of a Bond to Be Filed with the New York County NOTICE OF Clerk to Discharge Six Mechanic’s Liens Filed Against PETITION Real Property Known as 125 Broad Street, New York, New York by FINE CRAFTSMAN GROUP, LLC or Which may be Filed Regarding Performance Under a Certain Contract with FINE CRAFTSMAN GROUP, LLC at 125 Broad Street, New York, New York, Where Certain Lots Thereupon are Owned by SULLIVAN & CROMWELL, LLP, 125 ACQUISITION, LLC and THE AMERICAN CIVIL LIBERTIES UNION FOUNDATION, INC., and Interested Parties are THE 125 BROAD CONDOMINIUM, WELLS FARGO BANK N.A. and HARCO NATIONAL INSURANCE COMPANY, Respondents. ------------------------------------------------------------------------------X PLEASE TAKE NOTICE, that, upon the annexed Verified Petition of Jeremy Kalina, Esq. of Kalina & Mattia, P.C., attorneys for Petitioner 125 Broad CHP, LLC, dated and verified the 25th day of July, 2023, and the exhibits annexed thereto, the undersigned will move this Court, at the Motion Support Part, Room 130, in the Supreme Courthouse located at 60 Centre Street, New York, New York 10007, on the 28th day of August at 9:30 o’clock in the forenoon or as soon thereafter as counsel can be heard, for an Order pursuant to Lien Law §37 determining and setting the amount of a certain single lien discharge bond in the penal sum of $1,628,144.38, which Petitioner 125 Broad CHP, LLC may file with the New York County Clerk, which shall: (A) discharge six mechanic’s liens filed by Respondent Fine Craftsman Group, LLC against real property at 125 Broad Street, New York, New York 10004; and (B) which bond shall substitute for and replace the lien discharge bond previously filed by Petitioner 125 Broad CHP, LLC with the New York County Clerk that discharged one of the six mechanic’s liens Respondent Fine 1 1 of 4 FILED: NEW YORK COUNTY CLERK 07/25/2023 04:54 PM INDEX NO. 157429/2023 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 07/25/2023 Craftsman Group, LLC previously filed against real property at 125 Broad Street, New York, New York 10004; and (3) for such other and further relief as this Court may deem just and proper. PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR § 403 and CPLR § 2214, that answering papers, if any, shall be served at least seven days before the aforesaid return date. Petitioner designates New York County as the place of hearing or trial, as New York County is the County where the property against which the Respondent Fine Craftsman Group, LLC filed a total of six mechanic’s liens is located, which is the subject of this Petition. Dated: Woodbury, New York July 25, 2023 KALINA & MATTIA, P.C. Attorneys for Petitioner Jeremy Kalina ___________________________ By: Jeremy Kalina, Esq. 80 Crossways Park Drive, Suite 300 Woodbury, NY 11797 To: (516) 247-6445 Fine Craftsman Group, LLC 74-06 Metropolitan Avenue Middle Village, NY 11379 Sullivan & Cromwell LLP 125 Broad Street New York, NY 10004 125 Acquisition, LLC 125 Broad Street New York, NY 10004 The American Civil Liberties Union Foundation, Inc. 125 Broad Street New York, NY 10004 The 125 Broad Condominium 125 Broad Street New York, New York 10004 Wells Fargo Bank N.A. 150 East 42nd Street, 35th Floor New York, NY 10017 2 2 of 4 FILED: NEW YORK COUNTY CLERK 07/25/2023 04:54 PM INDEX NO. 157429/2023 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 07/25/2023 Harco National Insurance Company 4200 Six Forks Road, Suite 1400 Raleigh, NC 27609 3 3 of 4 FILED: NEW YORK COUNTY CLERK 07/25/2023 04:54 PM INDEX NO. 157429/2023 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 07/25/2023 Index No. SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK In the Matter of the Application of 125 BROAD CHP, LLC, Petitioner, For an Order Pursuant to Lien Law §37 Determining the Amount of a Bond to Be Filed with the New York County Clerk to Discharge Six Mechanic’s Liens Filed Against Real Property Known as 125 Broad Street, New York, New York by FINE CRAFTSMAN GROUP, LLC or Which may be Filed Regarding Performance Under a Certain Contract with FINE CRAFTSMAN GROUP, LLC at 125 Broad Street, New York, New York, Where Certain Lots Thereupon are Owned by SULLIVAN & CROMWELL, LLP, 125 ACQUISITION, LLC and THE AMERICAN CIVIL LIBERTIES UNION FOUNDATION, INC., and Interested Parties are THE 125 BROAD CONDOMINIUM, WELLS FARGO BANK N.A. and HARCO NATIONAL INSURANCE COMPANY, Respondents. NOTICE OF PETITION Signature (Rule 130-1.1-a Compliance) Jeremy Kalina KALINA & MATTIA, P.C. Attorneys for Petitioner 80 Crossways Park Drive Suite 300 Woodbury, NY 11797 (516) 247-6445 To Attorney(s) for Service of a copy of the within is hereby admitted. Dated, Attorney(s) for ......................................................... 4 4 of 4