On May 30, 2018 a ADJOURNMENT REQUEST submitted by HEINOLD, DOUGLAS, LYNN of RAYMOND COLEMAN HEINOLD LLP on behalf of JOHN S RADOMSKI, JOSEPH CAVALIERI, SCOTT G KERN, MARIE E KERN, CAROL L RADOMSKI against PENNROSE LLC was filed involving a dispute between Pennrose Llc, and Andre Oliveriera, Annette L Smith, Aparecida S Coutinho, Apc Associates Llc, Carl Muller, Carol L Radomski, Carol Muller, Chakrya K Molinoff, Charles Furlong, Christine E Herb, Christine Greatrex, Daniel Hanks, Daryl F Tonia, David Hercock, Diane Speer, Diego Castellanos, Doris G Blyler, Edward Mulka, Elizabeth Falco, Erika Gore, Eugene M Flacche, Eva Hanks, George C Greatrex Jr, George Freudenberg, Giovanna Ferriera, Hoover Quintero Garcia, Hui Y Shih, James E Weist, Jeffrey B Canfield, Jeffrey D Herb, Jeffrey L Molinoff, Joanne K Welch, John M Pfrommer, John S Radomski, Jose A Coutinho, Joseph Cavalieri, Karen Woznica, Katherine O Schimmel, Keenan Builders Llc, Lee H Schimmel, Margo Furlong, Marie E Kern, Ming T Shih, Muir A Mcmath, Paulette Smith, Rebecca Castellanos, Recon Investment Group Llc, Richard J Smith, Robert Gore, Robert Woznica, Ronnie M Tarchichi, Roseanne M Canfield, Russell Smith, Scott G Kern, Sigmund Tonia, Susan M Stevens, Syeda F Ahmed, Syed M Ahmed, Theodore J Speer Jr, Thomas B Mitchell, Umur Selek, Vito Brasile, Warren G Blyler, Wongsduan Mulka, for Mt. Laurel in the District Court of Burlington County.
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BUR-L-001147-18 11/18/2019 3:28:47 PM Pg 1 of2 Trans ID: LCV20192124829 Raymond|Cole man Heinoldup Stephen G. Raymond ‘Thomas J. Coleman, III* Douglas L. Heinold Janice L. Heinold* attorneys at law Stephen E, Raymond* 325 New Albany Road William H. Menges* Edward A. Kondracki* Moorestown, NJ 08057 *Also admitted to practice in the Commonwealth of Pennsylvania Tel. 856.222.0100 Fax 856.222.0411 Sof Counsel dheinold@ rclawnj.com November 18, 2019 Via E-Courts Honorable Paula T. Dow, J.S.C., P.J.Ch. Burlington County Superior Court Olde Courthouse, First Floor 49 Rancocas Road Mount Holly, NJ 08060 Re: Pennrose, LLC, v. Radomskis, et al. Docket No. BUR-L-1147-18 Dear Judge Dow: Please allow this letter to follow up on my prior letter of October 29" wherein I confirmed the settlement of this litigation. I just spoke to Victor Herlinsky, attorney for Pennrose, with regard to the status of the settlement agreements. We have received their proposed draft and they have received our comments. They will be working on responding to Mr. Smith (he is under a separate agreement) and us (all other defendants remaining in the case) as soon as possible. I anticipate that we should be able to finalize all agreements in short order. I would note that Mr. Herlinsky has had some health issues that have impacted his time in the office, and Mr. Carucci (of his office) was on vacation for a week. Finally, please note that there is a control date on this case set for November 21° at 10:00 am. I am scheduled to give a seminar for the New Jersey Institute of Local Government Attorneys in Atlantic City, and in speaking to Mr. Herlinsky, he will be in Atlantic City all day as well. I did not request an adjournment previously because I thought we would have a finalized stipulation filed by now. Given the above and that the parties continue to resolve final forms of agreement, I would respectfully ask that the court set this matter ahead to a date after the 21°. I apologize in advance for any inconvenience. BUR-L-001147-18 11/18/2019 3:28:47 PM Pg 2 of 2 Trans ID: LCV20192124829 November 18, 2019 I thank the Court for its time and courtesy in this matter. Respectfully submitted, RAYMOND COLEMAN HEINOLD, LLP ~~ DOUGLAS L. HEINOLD CC: All Parties via E-Courts Client List