On March 09, 2010 a
Letter,Correspondence
was filed
involving a dispute between
Kuplesky, Harold, Individually And On Behalf Of Starrett City Preservation Llc, Derivatively,
Rudman, Harvey, Individually And On Behalf Of Starrett City Preservation Llc, Derivatively,
and
Carol Gram Deane,
Dd Shopping Center Llc,
Dd Spring Creek Llc,
Disque D. Deane,
Salt Kettle Llc,
Sk Shopping Center Llc,
Sk Spring Creek Llc,
Spring Creek Plaza Llc,
Starrett City Preservation Llc,
St. Gervais Llc,
for Commercial Division
in the District Court of New York County.
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GOL,ENBOCK EISEMAN
Attorneys at Law 1 437 Madison Ave., New York, NY 10022-7020
ASSOR BELL & P~SKOE«P T (212) 907-7300 I F (212) 754-0330 I www.golenbock.com
DiRECr DiAC No.: (2 / 2J 907-739 /
DiRecr F.ax No.: l2 / 2) 754-0330
EMA/L ADDRESS: ✓VE/T~OOLENBOCK.COM
November 5, 2012
BY HAND DELIVERY
Hon. Shirley Werner Kornreich
Supreme Court of the State of New York
60 Centre Street, Rm. 418
New York, New York 10007
Re: Rudman, et al.; v. Deane, et al.
N.Y. Supreme, Index No. 650159/2010)
Dear Justice Kornreich:
We are counsel to plaintiffs in the above-referenced action. We write on behalf of
all parties to request extensions on certain dates scheduled for this week. Thursday, November
8, 2012 is currently the deadline for the completion of non-party and expert depositions, and
Friday, November 9, 2012 is the deadline for plaintiffs to file the Note of Issue. We also have a
conference scheduled with the Court on November 8, 2012 at 10:30 a.m.
We are in the midst of expert depositions, and had three expert depositions
scheduled to take place in recent days which would have allowed us to comply with the existing
deadlines. Hurricane Sandy, however, caused problems for the experts and attorneys alike,
necessitating the rescheduling of these depositions. We are in the process of rescheduling them,
but cannot complete them within the current deadlines.
We respectfully request that the conference and these deadlines be extended to the
week of November 26, 2012, with the conference on a date prior to the other deadlines. We are
available for a conference call with the Court if desired, but the telephone numbers we had for
the Court were not functioning.
veit
1644063.1
Document Filed Date
November 05, 2012
Case Filing Date
March 09, 2010
Category
Commercial Division
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GOL,ENBOCK EISEMAN Attorneys at Law 1 437 Madison Ave., New York, NY 10022-7020 ASSOR BELL & P~SKOE«P T (212) 907-7300 I F (212) 754-0330 I www.golenbock.com DiRECr DiAC No.: (2 / 2J 907-739 / DiRecr F.ax No.: l2 / 2) 754-0330 EMA/L ADDRESS: ✓VE/T~OOLENBOCK.COM November 5, 2012 BY HAND DELIVERY Hon. Shirley Werner Kornreich Supreme Court of the State of New York 60 Centre Street, Rm. 418 New York, New York 10007 Re: Rudman, et al.; v. Deane, et al. N.Y. Supreme, Index No. 650159/2010) Dear Justice Kornreich: We are counsel to plaintiffs in the above-referenced action. We write on behalf of all parties to request extensions on certain dates scheduled for this week. Thursday, November 8, 2012 is currently the deadline for the completion of non-party and expert depositions, and Friday, November 9, 2012 is the deadline for plaintiffs to file the Note of Issue. We also have a conference scheduled with the Court on November 8, 2012 at 10:30 a.m. We are in the midst of expert depositions, and had three expert depositions scheduled to take place in recent days which would have allowed us to comply with the existing deadlines. Hurricane Sandy, however, caused problems for the experts and attorneys alike, necessitating the rescheduling of these depositions. We are in the process of rescheduling them, but cannot complete them within the current deadlines. We respectfully request that the conference and these deadlines be extended to the week of November 26, 2012, with the conference on a date prior to the other deadlines. We are available for a conference call with the Court if desired, but the telephone numbers we had for the Court were not functioning. veit 1644063.1