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  • Michael Messina v. Morton Village Realty Inc., Phillips International Realty Inc. Tort document preview
  • Michael Messina v. Morton Village Realty Inc., Phillips International Realty Inc. Tort document preview
						
                                

Preview

QUINTAIROS, PRIETO, WOOD & BOYER, P.A. ATTORNEYS ATIAW WWW.QPWBIAW.COM 1250 Broadway, Suite 3502 New York,New Y o r k .10001 TELEPHONE: (212) 226-4026 FACSIMILE: (212) 226-4027 November 6, 2018 VIA EFILE AND REGULAR MAIL Honorable Steven M. Jaeger Nassau County Supreme Court 100 Supreme Court Drive Mineola, NY 11501 Re: Michael Messina v. Morton Village Realty Nassau County Index No.: 604204/2014 Dear Judge Jaeger: We write in response to the letter submitted by plaintiff's counsel da 2018. Although counsel attempts to complicate the matter, the issue is simple. obtain leave of Court to file a Reply on his cross-motion, nor did the parties Plaintiff's Reply is thus improper as CPLR § 2214(b) clearly states: "Only accordance with the provisions of this rule shall be read in support of, or in direct." motion, unless the court for good cause shall otherwise (cmphasis plaintiff submits vague and irrelevant case law, cent±½g no discussion of wh nhtnined leave of Court, the issue is clear based upon the plain reading of the C The matian is not yet decided and thus our objection is timely, contrar contention. We also appeared on the return date in Your Honor's courtroom counsel was not there. We were thus directed to submit a letter noting our objectio Reply, which we have done. We therefore respectfully submit that this Court s cc: VIA E-FILING AND MAIL DELL & DEAN, PLLC 1225 Franklin Avenue, Suite 450 Garden City, New York 11530 ARMIENTI DEBELLIS GUGLIEMO & RHODEN 170 Old Country Road, Suite 607 Mineola, NY 11501 CONGDON, FLAHERTY, O’CALLAGHEN, REID DONLON, TRAVIS & FISHLINGER 33 Earle Ovington Blvd, Suite 502 Uniondale, NY 11553 2