Document for 62-08 Realty Llc, Wlgt Holdings Llc, Ea 8th Ave Llc, Aa 8th Ave Llc, Eighth Ave Va Llc v. Msk Properties, Llc, Rmds Realty Associates, Llc, 745 64th Realty Associates, Llc, 6405 Seventh Avenue, Llc, Msk Properties Of Brooklyn, Llc

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                                FILED: NEW YORK COUNTY CLERK 06/11/2024 10:06 AM                                                                                INDEX NO. 652924/2024
NYSCEF DOC. NO. 9                                                                                                    RECEIVED NYSCEF: 06/11/2024


    Ross, Scott

    From:                                      Karen Frieman 
    Sent:                                      Monday, June 10, 2024 3:16 PM
    To:                                        Ross, Scott; Stewart J. Stern
    Cc:                                        Field, Daniel; Mehlman, Avery; Stewart J. Stern
    Subject:                                   RE: 62-08 et al v. MSK Properties




    Please let me know in advance of any appearance, including one including before your
    proposed OSC is signed. In addi on, in deference to the Jewish holiday this week, please do
    not include any return date or other appearance date for June 12 or 13, 2024.

    Thanks,

    Karen S. Frieman | Stern Tannenbaum & Bell LLP
    380 Lexington Avenue | New York, NY 10168
    Tel: 212-792-8490 | Fax: 212-792-8489
    kfrieman@sterntannenbaum.com
    www.sterntannenbaum.com


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    From: Ross, Scott 
    Sent: Monday, June 10, 2024 12:20 PM
    To: Karen Frieman ; Stewart J. Stern 
    Cc: Field, Daniel ; Mehlman, Avery 
    Subject: 62-08 et al v. MSK Properties



    Karen,

    Please be advised that tomorrow, June 11, 2024, at or around 10:00 A.M., 62-08 REALTY LLC, WLGT HOLDINGS LLC, EA
    8TH AVE LLC, AA 8TH AVE LLC, and EIGHTH AVE VA LLC (collec vely, the “Plain ffs”) will be filing a new ac on against MSK
    PROPERTIES, LLC, RMDS REALTY ASSOCIATES, LLC, 745 64TH REALTY ASSOCIATES, LLC, 6405 SEVENTH AVENUE, LLC, and
    MSK PROPERTIES OF BROOKLYN, LLC (collec vely, the “Defendants”) in New York County and in connec on therewith
    will be moving, by Order to Show Cause, for a TRO and preliminary injunc on: (i) staying and tolling the closing date set
    forth in § 7 of the Se lement Agreement between Plain ffs and Defendants; (ii) staying and tolling the date by which to
    extend the closing date set forth in § 7 of the Se lement Agreement; (iii) enjoining and restraining Defendants from
    entering onto Plain ffs’ property, located at 6200 Eighth Avenue, which is designated as Block 5794 Lot 75 on the tax
    map of Kings County (the “Property”); and (iv) requiring Defendants to obtain the authoriza on of their tenant – en es
    affiliated with Maimonides hospital – for Defendants to enter into a construc on license and access agreement, and any

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FILED: NEW YORK COUNTY CLERK 06/11/2024 10:06 AM                                                      INDEX NO. 652924/2024
NYSCEF DOC. NO. 9                                                                             RECEIVED NYSCEF: 06/11/2024
    other agreement contemplated by the Se lement Agreement, on behalf of Maimonides. I will send you the papers
    when they are ready and I will let you know if the Court indicates that an appearance is necessary.

    Regards,



      1    HERRICK
    Scott C. Ross
    Herrick, Feinstein LLP
    Two Park Avenue | New York, NY 10016
    212.592.1448 Office
    SRoss@herrick.com
    website bio




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    communication in error, please immediately notify us by return e-mail and delete the original and any copies.




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