On May 11, 2018 a
Letter,Correspondence
was filed
involving a dispute between
Td Bank, N.A.,
Wf Jamaica Llc,
and
Facility Source, Llc,
Facility Source Northeast Services, Llc,
Zurich American Insurance Company,
Zurich North America Insurance Company,
for Torts - Other (declaratory judgment)
in the District Court of New York County.
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Abrams, Gorelick,Friedman & Jacobson, LLP One BatteryPark Plaza Phone: 212-422-1200
Attorneys At Law 4th Floor Fax: 212-968-7573
New York,NY 10004 www.agfjlaw.com
September 18, 2019
Via email
Hon. W. Franc Perry, J.S.C.
Supreme Court of the State of New York
New York County, Part 23
80 Centre Street, Room 307
New York, New York 10007
Re : WF Jamaica LLC and TD Bank, N.A. v. Zurich North America et al.,
Index number 154432/2018
Our file:31824
Honorable Sir:
We represent Plaintiffs WF Jamaica LLC and TD Bank, N.A. (collectively "TD Bank")
in the above-referenced insurance coverage matter.
We write on behalf of all parties with a joint request to adjourn the Preliminary
Conference currently scheduled for Tuesday September 24, 2019.
The parties request to adjourn the Preliminary Conference by 60 days, to such time as the
Court deems proper.
The nature of the action is an action for declaratory judgment regarding the insurance
policy issued by the Zurich defendants to the Facility Source defendants.
The reason for this request is that the parties are engaged in settlement negotiations that,
if successful, would resolve all claims. The parties are scheduling a private mediation which is
expected to occur within the next two weeks.
This is the second request to adjourn this conference.
We thank you for your attention to this matter.
Respectfully submitted,
ABRAMS, GORELICK, FRIEDMAN &
JACOBSON, LLP
Thomas R. Maeglin
Abrams, Gorelick, Friedmaii & Jacobson, LLP
Attorneys At Law
Hon. W. Franc Perry, J.S.C.
Supreme Court of the State of New York
September 18, 2019
Page 2
To: [All parties via email]
COUGHLIN DUFFY LLP
Attorneys for Defendants Zurich
American Insurance Company and
Zurich North America Insurance Company
Wall Street Plaza
28th
88 Pine Street, FlOOr
New York, New York 10005
RUPP BAASE PFALZGRAF CUNNINGHAM LLC
Attorneys for Defendants Facility Source, LLC,
and Facility Source Northeast Services, LLC
1600 Liberty Building
Buffalo, New York 14202
Document Filed Date
September 23, 2019
Case Filing Date
May 11, 2018
Category
Torts - Other (declaratory judgment)
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Abrams, Gorelick,Friedman & Jacobson, LLP One BatteryPark Plaza Phone: 212-422-1200 Attorneys At Law 4th Floor Fax: 212-968-7573 New York,NY 10004 www.agfjlaw.com September 18, 2019 Via email Hon. W. Franc Perry, J.S.C. Supreme Court of the State of New York New York County, Part 23 80 Centre Street, Room 307 New York, New York 10007 Re : WF Jamaica LLC and TD Bank, N.A. v. Zurich North America et al., Index number 154432/2018 Our file:31824 Honorable Sir: We represent Plaintiffs WF Jamaica LLC and TD Bank, N.A. (collectively "TD Bank") in the above-referenced insurance coverage matter. We write on behalf of all parties with a joint request to adjourn the Preliminary Conference currently scheduled for Tuesday September 24, 2019. The parties request to adjourn the Preliminary Conference by 60 days, to such time as the Court deems proper. The nature of the action is an action for declaratory judgment regarding the insurance policy issued by the Zurich defendants to the Facility Source defendants. The reason for this request is that the parties are engaged in settlement negotiations that, if successful, would resolve all claims. The parties are scheduling a private mediation which is expected to occur within the next two weeks. This is the second request to adjourn this conference. We thank you for your attention to this matter. Respectfully submitted, ABRAMS, GORELICK, FRIEDMAN & JACOBSON, LLP Thomas R. Maeglin Abrams, Gorelick, Friedmaii & Jacobson, LLP Attorneys At Law Hon. W. Franc Perry, J.S.C. Supreme Court of the State of New York September 18, 2019 Page 2 To: [All parties via email] COUGHLIN DUFFY LLP Attorneys for Defendants Zurich American Insurance Company and Zurich North America Insurance Company Wall Street Plaza 28th 88 Pine Street, FlOOr New York, New York 10005 RUPP BAASE PFALZGRAF CUNNINGHAM LLC Attorneys for Defendants Facility Source, LLC, and Facility Source Northeast Services, LLC 1600 Liberty Building Buffalo, New York 14202