Preview
FILED: NEW YORK COUNTY CLERK 08/23/2019 02:11 PM INDEX NO. 654095/2019
NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 08/23/2019
REQUEST FOR JUDICIAL INTERVENTION For Court Use Only:
UCS-840 (rev.
07/29/2019) IAS Entry Date
New York Supreme COURT, COUNTY OF New York
Judge Assigned
Index No: 654095/2019 Date Index Issued: 07/18/2019
Enter the complete case caption. Do not use et al or et ano. If more space is needed, RJI Date
CAPTION: attach a caption rider sheet.
HIGH LINE DEVELOPMENT LLC
Plaintiff(s)/Petitioner(s)
-against-
NEATPPON CHELSEA LLC, JOHNNY WOOH
Defendant(s)/Respondent(s)
NATURE OF ACTION OR PROCEEDING: Check only one box and specify where indicated.
MATRIMONIAL COMMERCIAL
☐ Contested ☐ Business Entity (includes corporations, partnerships, LLCs, LLPs, etc.)
☒ Contract
NOTE: If there are children under the age of 18, complete and attach the
MATRIMONIAL RJI Addendum (UCS-840M). For Uncontested Matrimonial
actions, use the Uncontested Divorce RJI (UD-13). ☐ Insurance (where insurance company is a party, except arbitration)
☐ UCC (includes sales and negotiable instruments)
TORTS
☐ Other Commercial:
☐ Asbestos
NOTE: For Commercial Division assignment requests pursuant to 22 NYCRR
202.70(d), complete and attach the COMMERCIAL DIVISION RJI ADDENDUM
☐ Child Victims Act (UCS-840C).
REAL PROPERTY: How many properties does the application include?
☐ Environmental:
☐ Condemnation
☐ Medical, Dental, or Podiatric Malpractice
☐ Mortgage Foreclosure: ☐ Residential ☐ Commercial
☐ Motor Vehicle Property Address:
NOTE: For Mortgage Foreclosure actions involving a one to four-family, owner-
☐ Products Liability:
occupied residential property or owner-occupied condominium, complete and
attach the FORECLOSURE RJI ADDENDUM (UCS-840F).
☐ Other Negligence:
☐ Tax Certiorari - Section: Block: Lot:
☐ Other Professional Malpractice:
☐ Tax Foreclosure
☐ Other Tort:
☐ Other Real Property:
OTHER MATTERS SPECIAL PROCEEDINGS
☐ Certificate of Incorporation/Dissolution
[see NOTE in COMMERCIAL section] ☐ CPLR Article 75 (Arbitration)
[see NOTE in COMMERCIAL section]
☐ Emergency Medical Treatment ☐ CPLR Article 78 (Body or Officer)
☐ Habeas Corpus ☐ Election Law
☐ Local Court Appeal ☐ Extreme Risk Protective Order
☐ Mechanic's Lien ☐ MHL Article 9.60 (Kendra's Law)
☐ Name Change ☐ MHL Article 10 (Sex Offender Confinement-Initial)
☐ Pistol Permit Revocation Hearing ☐ MHL Article 10 (Sex Offender Confinement-Review)
☐ Sale or Finance of Religious/Not-for-Profit Property ☐ MHL Article 81 (Guardianship)
☐ Other: ☐ Other Mental Hygiene:
☐ Other Special Proceeding:
STATUS OF ACTION OR PROCEEDING: Answer YES or NO for every question and enter additional information where indicated.
YES NO
Has a summons and complaint or summons with notice been filed? ☒ ☐ If yes, date filed:
07/18/2019
Has a summons and complaint or summons with notice been served?☒ ☐ If yes, date served:
07/30/2019
Is this action/proceeding being filed post-judgment? ☐ ☒ If yes, judgment date:
1 of 2
FILED: NEW YORK COUNTY CLERK 08/23/2019 02:11 PM INDEX NO. 654095/2019
NATURE
NYSCEF OF NO.
DOC. JUDICIAL
19 INTERVENTION: RECEIVED NYSCEF:
Check one box only and enter additional information where indicated. 08/23/2019
☐ Infant's Compromise
☐ Extreme Risk Protective Order Application
☐ Note of Issue/Certificate of Readiness
☐ Notice of Medical, Dental, or Podiatric Malpractice
Date Issue Joined:
☒ Notice of Motion Relief Sought:
Judgment - Default Return Date:09/18/2019
☐ Notice of Petition Relief Sought: Return Date:
☐ Order to Show Cause Relief Sought: Return Date:
☐ Other Ex Parte Application Relief Sought:
☐ Poor Person Application
☐ Request for Preliminary Conference
☐ Residential Mortgage Foreclosure Settlement Conference
☐ Writ of Habeas Corpus
☐ Other:
RELATED CASES: List any related actions. For Matrimonial cases, list any related criminal or Family Court cases. If none, leave blank. If additional
space is required, complete and attach the RJI Addendum (UCS-840A).
Case Title Index/Case Number Court Judge (if assigned) Relationship to instant case
PARTIES: For parties without an attorney, check the "Un-Rep" box and enter the party's address, phone number and e-mail in the space provided. If
additional space is required, complete and attach the RJI Addendum (UCS-840A).
Parties Attorneys and/or Unrepresented Litigants Issue Joined Insurance Carriers
Un- List parties in same order as listed in
For represented parties, provide attorney's name, firm name,For each For each defendant,
the caption and indicate roles (e.g.,address, phone and email.
For unrepresented parties, provide defendant, indicate insurance
Rep plaintiff, defendant; 3rd party plaintiff,
party's address, phone and email. indicate if issue carrier, if
etc.) has been joined. applicable.
Name: HIGH LINE DEVELOPMENT LLC ANDREW PISTOR, Cyruli, Shanks, Hart & Zizmor LLP, 420 Lexington Ave
Ste 2320 , New York, NY 10170, apistor@cshzlaw.com
☐ Role(s): Plaintiff/Petitioner
YES
Name: NEATPPON CHELSEA LLC 355 West 14th Street, New York, NY 10011
☒ Role(s): Defendant/Respondent
NO
Name: WOOH, JOHNNY 48 9th Avenue, PHE, New York, NY 10011
☒ Role(s): Defendant/Respondent
NO
Name:
☐ Role(s):
Name:
☐ Role(s):
I AFFIRM UNDER THE PENALTY OF PERJURY THAT, UPON INFORMATION AND BELIEF, THERE ARE NO OTHER
RELATED ACTIONS OR PROCEEDINGS, EXCEPT AS NOTED ABOVE, NOR HAS A REQUEST FOR JUDICIAL
INTERVENTION BEEN PREVIOUSLY FILED IN THIS ACTION OR PROCEEDING.
Dated: 08/23/2019 ANDREW CHARLES PISTOR
Signature
4753612 ANDREW CHARLES PISTOR
Attorney Registration Number Print Name
This form was generated by NYSCEF
2 of 2
Preview
FILED: NEW YORK COUNTY CLERK 08/23/2019 02:11 PM INDEX NO. 654095/2019 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 08/23/2019 REQUEST FOR JUDICIAL INTERVENTION For Court Use Only: UCS-840 (rev. 07/29/2019) IAS Entry Date New York Supreme COURT, COUNTY OF New York Judge Assigned Index No: 654095/2019 Date Index Issued: 07/18/2019 Enter the complete case caption. Do not use et al or et ano. If more space is needed, RJI Date CAPTION: attach a caption rider sheet. HIGH LINE DEVELOPMENT LLC Plaintiff(s)/Petitioner(s) -against- NEATPPON CHELSEA LLC, JOHNNY WOOH Defendant(s)/Respondent(s) NATURE OF ACTION OR PROCEEDING: Check only one box and specify where indicated. MATRIMONIAL COMMERCIAL ☐ Contested ☐ Business Entity (includes corporations, partnerships, LLCs, LLPs, etc.) ☒ Contract NOTE: If there are children under the age of 18, complete and attach the MATRIMONIAL RJI Addendum (UCS-840M). For Uncontested Matrimonial actions, use the Uncontested Divorce RJI (UD-13). ☐ Insurance (where insurance company is a party, except arbitration) ☐ UCC (includes sales and negotiable instruments) TORTS ☐ Other Commercial: ☐ Asbestos NOTE: For Commercial Division assignment requests pursuant to 22 NYCRR 202.70(d), complete and attach the COMMERCIAL DIVISION RJI ADDENDUM ☐ Child Victims Act (UCS-840C). REAL PROPERTY: How many properties does the application include? ☐ Environmental: ☐ Condemnation ☐ Medical, Dental, or Podiatric Malpractice ☐ Mortgage Foreclosure: ☐ Residential ☐ Commercial ☐ Motor Vehicle Property Address: NOTE: For Mortgage Foreclosure actions involving a one to four-family, owner- ☐ Products Liability: occupied residential property or owner-occupied condominium, complete and attach the FORECLOSURE RJI ADDENDUM (UCS-840F). ☐ Other Negligence: ☐ Tax Certiorari - Section: Block: Lot: ☐ Other Professional Malpractice: ☐ Tax Foreclosure ☐ Other Tort: ☐ Other Real Property: OTHER MATTERS SPECIAL PROCEEDINGS ☐ Certificate of Incorporation/Dissolution [see NOTE in COMMERCIAL section] ☐ CPLR Article 75 (Arbitration) [see NOTE in COMMERCIAL section] ☐ Emergency Medical Treatment ☐ CPLR Article 78 (Body or Officer) ☐ Habeas Corpus ☐ Election Law ☐ Local Court Appeal ☐ Extreme Risk Protective Order ☐ Mechanic's Lien ☐ MHL Article 9.60 (Kendra's Law) ☐ Name Change ☐ MHL Article 10 (Sex Offender Confinement-Initial) ☐ Pistol Permit Revocation Hearing ☐ MHL Article 10 (Sex Offender Confinement-Review) ☐ Sale or Finance of Religious/Not-for-Profit Property ☐ MHL Article 81 (Guardianship) ☐ Other: ☐ Other Mental Hygiene: ☐ Other Special Proceeding: STATUS OF ACTION OR PROCEEDING: Answer YES or NO for every question and enter additional information where indicated. YES NO Has a summons and complaint or summons with notice been filed? ☒ ☐ If yes, date filed: 07/18/2019 Has a summons and complaint or summons with notice been served?☒ ☐ If yes, date served: 07/30/2019 Is this action/proceeding being filed post-judgment? ☐ ☒ If yes, judgment date: 1 of 2 FILED: NEW YORK COUNTY CLERK 08/23/2019 02:11 PM INDEX NO. 654095/2019 NATURE NYSCEF OF NO. DOC. JUDICIAL 19 INTERVENTION: RECEIVED NYSCEF: Check one box only and enter additional information where indicated. 08/23/2019 ☐ Infant's Compromise ☐ Extreme Risk Protective Order Application ☐ Note of Issue/Certificate of Readiness ☐ Notice of Medical, Dental, or Podiatric Malpractice Date Issue Joined: ☒ Notice of Motion Relief Sought: Judgment - Default Return Date:09/18/2019 ☐ Notice of Petition Relief Sought: Return Date: ☐ Order to Show Cause Relief Sought: Return Date: ☐ Other Ex Parte Application Relief Sought: ☐ Poor Person Application ☐ Request for Preliminary Conference ☐ Residential Mortgage Foreclosure Settlement Conference ☐ Writ of Habeas Corpus ☐ Other: RELATED CASES: List any related actions. For Matrimonial cases, list any related criminal or Family Court cases. If none, leave blank. If additional space is required, complete and attach the RJI Addendum (UCS-840A). Case Title Index/Case Number Court Judge (if assigned) Relationship to instant case PARTIES: For parties without an attorney, check the "Un-Rep" box and enter the party's address, phone number and e-mail in the space provided. If additional space is required, complete and attach the RJI Addendum (UCS-840A). Parties Attorneys and/or Unrepresented Litigants Issue Joined Insurance Carriers Un- List parties in same order as listed in For represented parties, provide attorney's name, firm name,For each For each defendant, the caption and indicate roles (e.g.,address, phone and email. For unrepresented parties, provide defendant, indicate insurance Rep plaintiff, defendant; 3rd party plaintiff, party's address, phone and email. indicate if issue carrier, if etc.) has been joined. applicable. Name: HIGH LINE DEVELOPMENT LLC ANDREW PISTOR, Cyruli, Shanks, Hart & Zizmor LLP, 420 Lexington Ave Ste 2320 , New York, NY 10170, apistor@cshzlaw.com ☐ Role(s): Plaintiff/Petitioner YES Name: NEATPPON CHELSEA LLC 355 West 14th Street, New York, NY 10011 ☒ Role(s): Defendant/Respondent NO Name: WOOH, JOHNNY 48 9th Avenue, PHE, New York, NY 10011 ☒ Role(s): Defendant/Respondent NO Name: ☐ Role(s): Name: ☐ Role(s): I AFFIRM UNDER THE PENALTY OF PERJURY THAT, UPON INFORMATION AND BELIEF, THERE ARE NO OTHER RELATED ACTIONS OR PROCEEDINGS, EXCEPT AS NOTED ABOVE, NOR HAS A REQUEST FOR JUDICIAL INTERVENTION BEEN PREVIOUSLY FILED IN THIS ACTION OR PROCEEDING. Dated: 08/23/2019 ANDREW CHARLES PISTOR Signature 4753612 ANDREW CHARLES PISTOR Attorney Registration Number Print Name This form was generated by NYSCEF 2 of 2