Letter,Correspondence: Woodmart Llc Vs Ardel Construction & Design G

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                                BER-L-006246-22 07/20/2023 3:37:23 PM Pg 1 of 3 Trans ID: LCV20232140424




Craig B. Novak | Associate
201.373.8941
cnovak@floriolaw.com



                                                    July 20, 2023
Via E-Courts
Hon. Mary F. Thurber, J.S.C.
Superior Court of New Jersey, Bergen County
10 Main Street
Hackensack, NJ 07601

        RE:     Woodmart LLC d/b/a Prime Cabintree v. Ardel Construction & Design
                Group Corp. d/b/a Ardel Living
                Docket No.: BER-L-6246-22
                Our File No.: 57358.0006

Dear Hon. Thurber:

       As Your Honor is aware, my office represents Defendant Judgment-Debtor Ardel
Construction & Design Group Corp. in the above referenced matter.

       On or about June 19, 2023, Your Honor signed a Consent Order to Turn Over Funds. The
signed Order was subsequently served upon Chase Bank, with a request that Chase Bank turn over
the funds in accordance with the terms of the Order.

         However, Chase Bank has still not released the funds. We have been advised that Chase
is resisting compliance with the Consent Order because it does not want to see the word “Consent”’
in the caption. Further, we have also been advised that Chase has an issue with how the Consent
Order directs the Sheriff to turn over the funds, and not Chase. While the attorneys in this case
understand this to be standard procedure, we respectfully request that Your Honor enter a revised
Order which should resolve Chase’s concerns. Kindly note that the parties consent to the enclosed
Order, but it is not structured in the form of a Consent Order due to Chase’s concerns.

        Please let me know if Your Honor has any questions. I can be reached on my direct line at
(201)-373-8941, or on my cell phone at (908)-347-4027. We thank the Court for its time and
attention to this matter.

                                                    Respectfully Submitted,
                                                    FLORIO PERRUCCI STEINHARDT
                                                    CAPPELLI TIPTON & TAYLOR, LLC


                                                    By: ___________________________
                                                        Craig B. Novak, Esq.
cc:     Justin H. Scheier, Esq.
       BER-L-006246-22 07/20/2023 3:37:23 PM Pg 2 of 3 Trans ID: LCV20232140424




FLORIO PERRUCCI STEINHARDT CAPPELLI TIPTON & TAYLOR, LLC
Craig B. Novak, Esq. (Atty ID No.: 008872012)
430 Mountain Avenue, Suite 103
New Providence, New Jersey 07974
(201) 843-5858
ltaylor@floriolaw.com
cnovak@floriolaw.com
Attorneys for Defendant Judgment-Debtor Ardel Construction & Design Group Corp.

  WOODMART LLC d/b/a PRIME
  CABINETREE,                                      SUPERIOR COURT OF NEW JERSEY
                                                   LAW DIVISION: BERGEN COUNTY
              Plaintiff,
  v.                                               DOCKET NO.: BER-L-6246-22

  ARDEL CONSTRUCTION & DESIGN                                       Civil Action
  GROUP CORP. d/b/a ARDEL LIVING,
                                                                  ORDER
              Defendants.                                   TO TURN OVER FUNDS




        This matter having been opened to the Court by Florio Perrucci Steinhardt Cappelli Tipton

& Taylor, LLC, counsel for Defendant Judgment-Debtor, Ardel Construction & Design Group

Corp. (“Defendant”), on notice to and with the consent of the Scheier Law Firm, LLC, counsel for

the Plaintiff Judgment-Creditor, Woodmart LLC;

        IT IS on this ________ day of ________________________, 2023; ORDERED AS

FOLLOWS:

        1.     CHASE BANK, N.A. shall pay directly to the Scheier Law Firm LLC (500 Post

Road East, Suite 263, Westport, Connecticut, 06880) the sum of FOURTEEN THOUSAND

ONE HUNDRED AND NINETEEN DOLLARS AND THIRTY-FOUR CENTS ($14,119.34),

which has been levied upon by the Morris County Sherriff, on behalf of and/or for the benefit and

direction of The Scheier Law Firm LLC as attorneys for PLAINTIFF, on the account belonging to

Defendant ending in last four digits 6215.
     BER-L-006246-22 07/20/2023 3:37:23 PM Pg 3 of 3 Trans ID: LCV20232140424




       2.      A copy of this Order shall be deemed served upon all counsel of record upon its

posting via eCourts online.




                                                  ____________________________________
                                                                                 J.S.C.




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