On July 26, 2019 a
Letter,Correspondence
was filed
involving a dispute between
223 Troutman, Llc,
and
Lucy Morrone Tamburino And Maria Ivers As Preliminary Co-Executors Of The Estate Of Rosina Morrone And The Estate Of Rosina Morrone,
for Commercial Division
in the District Court of New York County.
Preview
)
YORK kK DIV INDEX NO. 654280/2019
NYSCEF BOC. NO. 44 RECEIVED NYSCEF: 01/30/2020
THE SILBER LAW Fir, LLC
11 BROADWAY - SUITE 715
NEW YORK. NEW YORK 10004
TELEPHONE: (212) 765-4567
MEYERY. SILBER FACSIMILE: (212) 504-8165
MSTLBER@SILBERLAWNY.COM
342 BEDFORD AVENUE
DANIELLE I. PEDRAS BROOKLYN, NEW YORK 11211
DPEDRAS@SILBERLAWNY.COM
TELEPHONE: (718) 599-3500
January 27. 2020
Hon. Joel M. Cohen
Supreme Court of the State of New York
County of New York
60 Centre Street
Commercial Division, Room 570 — Part 3
New York, New York 10007
Re: 223 Troutman, LLC v. Tambarino, et al.; Index No. 654280/19
Dear Judge Cohen:
This Firm represents plaintiff in this action.
| write to ask the Court’s indul gence in accepting piaintiff's opposition papers one day
later than the parties had agreed.
The papers were due on Friday, January 24, 2020. On Friday, | reached out to
defendants’ counsel to inform him that | could resolve the case and close on the subject
property. Given his repeated statements that his clients were eager to do so, | assumed we
would settle and these papers would be unnecessary. | was shocked when counsel
responded and included a new and unacceptable term to settle. By the time | received
that
information, late on Friday afternoon, | could not compiete and file these papers.
(Subsequently, over the weekend, | thought | could discontinue the case, but | was
mistaken).
Accordingly, | have filed them on the next business day and ask that they be
accepted by the Court. Given the relationship with counsel, | have not asked his consent.
Res fully submitted
yer Y. Silber
by NYSCEF
In view of the circumstances, the papers will be accepted. The Court expects
counsel to maintain a working relationship, so that reasonable requests can be
.
made and, where appropriate, accepted.
41 (Qo (f 1120 , HON. JOEL M. COHEN
Document Filed Date
January 30, 2020
Case Filing Date
July 26, 2019
Category
Commercial Division
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) YORK kK DIV INDEX NO. 654280/2019 NYSCEF BOC. NO. 44 RECEIVED NYSCEF: 01/30/2020 THE SILBER LAW Fir, LLC 11 BROADWAY - SUITE 715 NEW YORK. NEW YORK 10004 TELEPHONE: (212) 765-4567 MEYERY. SILBER FACSIMILE: (212) 504-8165 MSTLBER@SILBERLAWNY.COM 342 BEDFORD AVENUE DANIELLE I. PEDRAS BROOKLYN, NEW YORK 11211 DPEDRAS@SILBERLAWNY.COM TELEPHONE: (718) 599-3500 January 27. 2020 Hon. Joel M. Cohen Supreme Court of the State of New York County of New York 60 Centre Street Commercial Division, Room 570 — Part 3 New York, New York 10007 Re: 223 Troutman, LLC v. Tambarino, et al.; Index No. 654280/19 Dear Judge Cohen: This Firm represents plaintiff in this action. | write to ask the Court’s indul gence in accepting piaintiff's opposition papers one day later than the parties had agreed. The papers were due on Friday, January 24, 2020. On Friday, | reached out to defendants’ counsel to inform him that | could resolve the case and close on the subject property. Given his repeated statements that his clients were eager to do so, | assumed we would settle and these papers would be unnecessary. | was shocked when counsel responded and included a new and unacceptable term to settle. By the time | received that information, late on Friday afternoon, | could not compiete and file these papers. (Subsequently, over the weekend, | thought | could discontinue the case, but | was mistaken). Accordingly, | have filed them on the next business day and ask that they be accepted by the Court. Given the relationship with counsel, | have not asked his consent. Res fully submitted yer Y. Silber by NYSCEF In view of the circumstances, the papers will be accepted. The Court expects counsel to maintain a working relationship, so that reasonable requests can be . made and, where appropriate, accepted. 41 (Qo (f 1120 , HON. JOEL M. COHEN