On July 16, 2019 a
Stipulation,Agreement
was filed
involving a dispute between
Derek Florimon,
and
251 Kane Street, Llc,
City Of New York,
Elizabeth Forman,
Josephine Owen,
Marcia Owen,
New York City Department Of Parks And Recreation,
New York City Department Of Transportation,
Owen Realty,
for Torts - Other (Premises)
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 08/28/2019 03:09 PM INDEX NO. 515540/2019
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 08/28/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
-----------------------------------------------------------x
DEREK FLORIMON, Index No. 515540/2019
Plaintiff,
STIPULATION EXTENDING
-against- TIME TO FILE RESPONSIVE
PLEADING
251 KANE STREET LLC, OWEN REALTY, MARCIA
OWEN, JOSEPHINE OWEN, ELIZABETH FORMAN, CITY
OF NEW YORK, NEW YORK CITY DEPARTMENT OF
TRANSPORTATION and NEW YORK CITY
DEPARTMENT OF PARKS AND RECREATION
Defendants.
---------------------------------------------------------------------x
IT IS HEREBY STIPULATED AND AGREED, that the time for Defendants 251
KANE STREET LLC, OWEN REALTY, MARCIA OWEN, and JOSEPHINE OWEN to appear
and to answer, amend, or supplement the answer as of course, or to make any motion with
relation to the Verified Complaint, shall be and hereby is extended for a period of thirty (30)
days.
IT IS FURTHER STIPULATED AND AGREED, that Defendants 251 KANE
STREET LLC, OWEN REALTY, MARCIA OWEN, and JOSEPHIN.E OWEN agree not to
raise personal jurisdiction as a defense.
IT IS FURTHER STIPULATED AND AGREED, that this Stipulation may be signed
in counterpart, and that a copy with facsimile or electronic signatures may be filed in lieu of the
original.
1 of 2
FILED: KINGS COUNTY CLERK 08/28/2019 03:09 PM INDEX NO. 515540/2019
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 08/28/2019
Dated: Cedar Grove, New Jers
August
NicT1olas erak Michael C/,E/wrnerg, Esq.
ELEFTERAKIS, ELEFTERAKIS & O'TOOLE SCRIVO, LLC
PANEK Attorneys for Defendants 251 Kane Street, LLC,
Attorneys for PlaintiffDerek Florimon Owen Realty, Marcia Owen, and Josephine
38th
80 Pine Street, FlOOr Owen
New York, New York 10005 14 Village Park Road
(212) 532-1116 Cedar Grove, New Jersey 07009
(973) 239-5700
File No.: 1140-417
2
2 of 2
Document Filed Date
August 28, 2019
Case Filing Date
July 16, 2019
Category
Torts - Other (Premises)
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Preview
FILED: KINGS COUNTY CLERK 08/28/2019 03:09 PM INDEX NO. 515540/2019 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 08/28/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS -----------------------------------------------------------x DEREK FLORIMON, Index No. 515540/2019 Plaintiff, STIPULATION EXTENDING -against- TIME TO FILE RESPONSIVE PLEADING 251 KANE STREET LLC, OWEN REALTY, MARCIA OWEN, JOSEPHINE OWEN, ELIZABETH FORMAN, CITY OF NEW YORK, NEW YORK CITY DEPARTMENT OF TRANSPORTATION and NEW YORK CITY DEPARTMENT OF PARKS AND RECREATION Defendants. ---------------------------------------------------------------------x IT IS HEREBY STIPULATED AND AGREED, that the time for Defendants 251 KANE STREET LLC, OWEN REALTY, MARCIA OWEN, and JOSEPHINE OWEN to appear and to answer, amend, or supplement the answer as of course, or to make any motion with relation to the Verified Complaint, shall be and hereby is extended for a period of thirty (30) days. IT IS FURTHER STIPULATED AND AGREED, that Defendants 251 KANE STREET LLC, OWEN REALTY, MARCIA OWEN, and JOSEPHIN.E OWEN agree not to raise personal jurisdiction as a defense. IT IS FURTHER STIPULATED AND AGREED, that this Stipulation may be signed in counterpart, and that a copy with facsimile or electronic signatures may be filed in lieu of the original. 1 of 2 FILED: KINGS COUNTY CLERK 08/28/2019 03:09 PM INDEX NO. 515540/2019 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 08/28/2019 Dated: Cedar Grove, New Jers August NicT1olas erak Michael C/,E/wrnerg, Esq. ELEFTERAKIS, ELEFTERAKIS & O'TOOLE SCRIVO, LLC PANEK Attorneys for Defendants 251 Kane Street, LLC, Attorneys for PlaintiffDerek Florimon Owen Realty, Marcia Owen, and Josephine 38th 80 Pine Street, FlOOr Owen New York, New York 10005 14 Village Park Road (212) 532-1116 Cedar Grove, New Jersey 07009 (973) 239-5700 File No.: 1140-417 2 2 of 2