On May 06, 2020 a
Letter,Correspondence
was filed
involving a dispute between
David A Mazie,
Kirsh, Gelband & Stone, P.A.,
Mazie Slater Katz &Freeman,
and
Bruce H Nagel,
David Mazie,
Gregg A Stone,
Mazie Slater Katz &Freeman,
Nagel Rice Llc,
for Complex Commercial
in the District Court of Essex County.
Preview
ESX-L-003110-20 09/01/2021 11:40:10 AM Pg 1 of 1 Trans ID: LCV20212026118
MAZIE SLATER KATZ & FREEMAN, LLC
103 Eisenhower Parkway, Suite 207, Roseland, NJ 07068
Phone: (973) 228-9898 - Fax: (973) 228-0303
www.mazieslater.com
David A. Mazie* Writer’s Email: Karen G. Kelsen°
Adam M. Slater*° 973-228-9911 Cheryll A. Calderon
Eric D. Katz*° dmazie@mazieslater.com Adam M. Epstein°
David M. Freeman Cory J. Rothbort*°
Beth G. Baldinger Michael R. Griffith°
Matthew R. Mendelsohn° Christopher J. Geddis
David M. Estes Alexander Q. Reynoso
Samuel G. Wildman
*Certified by the Supreme Court of Julia S. Slater°
New Jersey as a Civil Trial Attorney September 1, 2021
°Member of N.J. & N.Y. Bars
VIA ECOURTS
Honorable Thomas R. Vena, J.S.C.
Essex County Superior Court
Historic Courthouse
470 Dr. Martin Luther Jr. Blvd.
Newark, New Jersey 07102
Re: Kirsch Gelband & Stone v. Mazie, et al.
Docket No.: ESX-L-3110-20
Dear Judge Vena:
I write in response to Mr. Nagel’s letter regarding a date for the filing of his responsive
pleading. To be clear, there was absolutely no such discussion during the Case Management
Conference regarding the return date of any motion to dismiss being set for December 3rd. My
recollection is that Your Honor stated that you would handle motions as they are filed, and that if
there are motions pending at the time of the Case Management Conference then you will address
them at that time in the ordinary course.
As a reminder, the subject counterclaim and third-party complaint were filed on July 16,
2021 with Mr. Nagel not signing the acknowledgment of service until August 3. Under the Court
Rules, Mr. Nagel has until September 7 to file a responsive pleading. Although we previously
agreed to a two-week extension, we are willing to extend his time to answer for 30 days until
October 7. That is more than five weeks from now and is more than enough time for him to file
any motion he intends to file. There is simply no justifiable basis for any further delay especially
in light of the Court’s discovery deadlines which require that all written discovery and party
depositions be completed by December 3.
Respectfully submitted,
DAVID A. MAZIE
DAM/dmd
cc: All counsel (Via E-Courts)
Document Filed Date
September 01, 2021
Case Filing Date
May 06, 2020
Category
Complex Commercial
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ESX-L-003110-20 09/01/2021 11:40:10 AM Pg 1 of 1 Trans ID: LCV20212026118 MAZIE SLATER KATZ & FREEMAN, LLC 103 Eisenhower Parkway, Suite 207, Roseland, NJ 07068 Phone: (973) 228-9898 - Fax: (973) 228-0303 www.mazieslater.com David A. Mazie* Writer’s Email: Karen G. Kelsen° Adam M. Slater*° 973-228-9911 Cheryll A. Calderon Eric D. Katz*° dmazie@mazieslater.com Adam M. Epstein° David M. Freeman Cory J. Rothbort*° Beth G. Baldinger Michael R. Griffith° Matthew R. Mendelsohn° Christopher J. Geddis David M. Estes Alexander Q. Reynoso Samuel G. Wildman *Certified by the Supreme Court of Julia S. Slater° New Jersey as a Civil Trial Attorney September 1, 2021 °Member of N.J. & N.Y. Bars VIA ECOURTS Honorable Thomas R. Vena, J.S.C. Essex County Superior Court Historic Courthouse 470 Dr. Martin Luther Jr. Blvd. Newark, New Jersey 07102 Re: Kirsch Gelband & Stone v. Mazie, et al. Docket No.: ESX-L-3110-20 Dear Judge Vena: I write in response to Mr. Nagel’s letter regarding a date for the filing of his responsive pleading. To be clear, there was absolutely no such discussion during the Case Management Conference regarding the return date of any motion to dismiss being set for December 3rd. My recollection is that Your Honor stated that you would handle motions as they are filed, and that if there are motions pending at the time of the Case Management Conference then you will address them at that time in the ordinary course. As a reminder, the subject counterclaim and third-party complaint were filed on July 16, 2021 with Mr. Nagel not signing the acknowledgment of service until August 3. Under the Court Rules, Mr. Nagel has until September 7 to file a responsive pleading. Although we previously agreed to a two-week extension, we are willing to extend his time to answer for 30 days until October 7. That is more than five weeks from now and is more than enough time for him to file any motion he intends to file. There is simply no justifiable basis for any further delay especially in light of the Court’s discovery deadlines which require that all written discovery and party depositions be completed by December 3. Respectfully submitted, DAVID A. MAZIE DAM/dmd cc: All counsel (Via E-Courts)