On August 17, 2023 a
STIPULATION - ADJOURNMENT OF MOTION -IN SUBMISSIONS PART -RM 130
was filed
involving a dispute between
Alx C21 Llc,
Rego Ii Borrower Llc,
and
Gindi C21 Ip Llc,
Raymond Gindi,
Wf Blue Llc,
for Commercial - Contract - Commercial Division
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 11/22/2023 04:42 PM INDEX NO. 653993/2023
NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 11/22/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
------------------------------------------------------------------------ X
ALX C21 LLC and REGO II BORROWER LLC,
Index No. 653993/2023
Plaintiffs,
– against –
STIPULATION
WF BLUE LLC, GINDI C21 IP LLC, and RAYMOND
GINDI,
Defendants.
------------------------------------------------------------------------ X
IT IS HEREBY STIPULATED AND AGREED, by and between plaintiffs ALX C21
LLC and REGO II BORROWER LLC (collectively, “Plaintiffs”) and defendants WF BLUE LLC,
GINDI C21 IP LLC, and RAYMOND GINDI (collectively, “Defendants”), through their
undersigned attorneys, as follows:
1. Defendants’ motion by notice of motion dated November 10, 2023 (Motion Seq. 1;
NYSCEF Doc. Nos. 6-13; the “Motion for Partial Dismissal”), presently returnable in the Court’s
Motion Part on December 8, 2023, is hereby adjourned to January 30, 2024.
2. Plaintiffs shall e-file any opposition or cross-motion responding to the Motion for
Partial Dismissal on or before January 5, 2024.
3. Defendants shall e-file any reply on the Motion for Partial Dismissal and opposition
to any cross-motion on or before January 29, 2024.
4. Except as expressly set forth above, the terms and conditions of this stipulation are
without prejudice to, and nothing contained herein shall be deemed to constitute a modification,
waiver, release or relinquishment of, any of the parties’ respective claims, defenses, rights or
remedies, all of which are expressly reserved.
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FILED: NEW YORK COUNTY CLERK 11/22/2023 04:42 PM INDEX NO. 653993/2023
NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 11/22/2023
5. This stipulation may not be changed orally, shall be deemed to have been prepared
by all parties and shall be construed without regard to any presumption or other rule requiring
construction against the party causing it to be drafted.
6. This stipulation is offered for signature and it is understood and agreed that this
stipulation shall not be binding until executed by or on behalf of the parties as set forth below.
Upon such execution, this stipulation shall be binding upon the parties, their heirs, executors,
administrators, affiliates, parents, subsidiaries, successors and assigns.
7. This stipulation may be executed in counterparts and signatures transmitted by e-
mail, facsimile or other electronic means shall be deemed original for the purposes hereof.
Dated: November 22, 2023
New York, NY
GREENBERG TRAURIG, LLP OVED & OVED LLP
Attorneys for Plaintiffs Attorneys for Defendants
One Vanderbilt Avenue 401 Greenwich Street
New York, NY 10017 New York, NY 10013
(212) 801-9200 (212) 226-2700
By: _______________________ By: /s/ Andrew J. Urgenson (w/ consent)
_______________________
Daniel J. Ansell Darren Oved
Matthew Handler Andrew J. Urgenson
-2-
2 of 2
Document Filed Date
November 22, 2023
Case Filing Date
August 17, 2023
Category
Commercial - Contract - Commercial Division
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FILED: NEW YORK COUNTY CLERK 11/22/2023 04:42 PM INDEX NO. 653993/2023 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 11/22/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ------------------------------------------------------------------------ X ALX C21 LLC and REGO II BORROWER LLC, Index No. 653993/2023 Plaintiffs, – against – STIPULATION WF BLUE LLC, GINDI C21 IP LLC, and RAYMOND GINDI, Defendants. ------------------------------------------------------------------------ X IT IS HEREBY STIPULATED AND AGREED, by and between plaintiffs ALX C21 LLC and REGO II BORROWER LLC (collectively, “Plaintiffs”) and defendants WF BLUE LLC, GINDI C21 IP LLC, and RAYMOND GINDI (collectively, “Defendants”), through their undersigned attorneys, as follows: 1. Defendants’ motion by notice of motion dated November 10, 2023 (Motion Seq. 1; NYSCEF Doc. Nos. 6-13; the “Motion for Partial Dismissal”), presently returnable in the Court’s Motion Part on December 8, 2023, is hereby adjourned to January 30, 2024. 2. Plaintiffs shall e-file any opposition or cross-motion responding to the Motion for Partial Dismissal on or before January 5, 2024. 3. Defendants shall e-file any reply on the Motion for Partial Dismissal and opposition to any cross-motion on or before January 29, 2024. 4. Except as expressly set forth above, the terms and conditions of this stipulation are without prejudice to, and nothing contained herein shall be deemed to constitute a modification, waiver, release or relinquishment of, any of the parties’ respective claims, defenses, rights or remedies, all of which are expressly reserved. 1 of 2 FILED: NEW YORK COUNTY CLERK 11/22/2023 04:42 PM INDEX NO. 653993/2023 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 11/22/2023 5. This stipulation may not be changed orally, shall be deemed to have been prepared by all parties and shall be construed without regard to any presumption or other rule requiring construction against the party causing it to be drafted. 6. This stipulation is offered for signature and it is understood and agreed that this stipulation shall not be binding until executed by or on behalf of the parties as set forth below. Upon such execution, this stipulation shall be binding upon the parties, their heirs, executors, administrators, affiliates, parents, subsidiaries, successors and assigns. 7. This stipulation may be executed in counterparts and signatures transmitted by e- mail, facsimile or other electronic means shall be deemed original for the purposes hereof. Dated: November 22, 2023 New York, NY GREENBERG TRAURIG, LLP OVED & OVED LLP Attorneys for Plaintiffs Attorneys for Defendants One Vanderbilt Avenue 401 Greenwich Street New York, NY 10017 New York, NY 10013 (212) 801-9200 (212) 226-2700 By: _______________________ By: /s/ Andrew J. Urgenson (w/ consent) _______________________ Daniel J. Ansell Darren Oved Matthew Handler Andrew J. Urgenson -2- 2 of 2