Stipulation,Agreement: Richard J. Digeronimo, R.D. Geronimo, Ltd v. Property Analytix, Llc, Archstone Group Nyc Llc, Michael Miller, Royce Ashton Rowles, Ryan Lin

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                                SUPREME COURT OF THE STATE OF NEW YORK
 COUNTY OF WESTCHESTER

 NEIL B. RICE,
                                   Plaintiff,
                                                             Index No. 61665/2021
         v.

LEE R. EINSIDLER, As Administrator of the Estate             STIPULATION AND
of Aaron Michael Einsidler aka Aaron M. Einsidler,           [PROPOSED] ORDER
                                                             ADJOURNING DISCOVERY
                                   Defendant.                DEADLINES


        WHEREAS, on August 25, 2021, Plaintiff NEIL B. RICE (“Plaintiff”) filed the Summons

and Complaint against Defendant LEE R. EINSIDLER (“Defendant”), as Administrator of the

Estate of Aaron Michael Einsidler;

        WHEREAS, on March 14, 2022, Defendant filed an answer to the Complaint;

        WHEREAS, on March 28, 2022, the Court so-ordered a Preliminary Conference

Stipulation submitted by the parties (the “PC Order”);

        WHEREAS, the deadlines in the PC Order have previously been extended by the Court at

the request of the parties;

        WHEREAS, on March 14, 2023, the parties submitted a joint letter requesting an

approximately three-month extension of the discovery deadlines (Doc. No. 126) (the “Extension

Request”) due to ongoing discovery and the pendency of motions to compel that are ripe for

decision by the Court; and

        WHEREAS, a court conference was conducted in person on March 21, 2023 with counsel

for the parties present, during which the Court indicated that it had reviewed the Extension Request

and was amenable to the requested extensions and requested that the parties submit a proposed

order reflecting the proposed amended schedule;
       IT IS HEREBY STIPULATED AND AGREED, subject to approval by the Court, that

the deadlines set forth in the PC Order are extended as follows:

           1. The deadline for Plaintiff’s EBT is extended to June 16, 2023;

           2. The deadline for Defendant’s EBT is extended to July 13, 2023;

           3. The deadline set forth in Item 7(a) of the PC Order for the exchange of names and

              addresses of all witnesses, and exchange of statements of opposing parties and

              photographs, is extended to August 11, 2023;

           4. The deadline for depositions of non-parties is extended to September 1, 2023;

           5. The deadline for all disclosure is extended to September 22, 2023; and

           6. Any deadlines not identified herein that are tethered to any of the above deadlines

              are extended to trigger from the applicable new deadline.


Dated: White Plains, New York
       March 29, 2023


        ROSMAN LEGAL, P.C.                               YANKWITT LLP


        By: ___________________________                  By: __________________________
        Robert S. Rosman                                 Jonathan Ohring
        Steven M. Brunnlehrman                           140 Grand Street, Suite 705
        7-11 South Broadway, Suite 308                   White Plains, NY
        White Plains, NY 10601                           (914) 352-4788
        (914) 339-9870                                   jonathan@yankwitt.com
        rob@rosmanlegal.com
        steve@rosmanlegal.com                            Attorneys for Defendant

        Attorneys for Plaintiff




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    ORDERED:


    ________________________
    Hon. Hal B. Greenwald, J.S.C.




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