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.
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THE SILBER LAw FIRM, LLC
11 BROADWAY · SUITE 71S
NEW YORK. NEW YORK 10004
TELEPHONE: (212) 76S-4567
MEYERY. 51LBER FACSIMILE: (212) 504-816S
MSILBER@$1LBERLAWNY.COM 342 BEDFORD AVENUE
DANIELLEL 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 Room 570 - Part 3
Division,
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.
I write to ask the Court's indulgence in accepting plaintiff's opposition papers one day
later than the parties had agreed.
The papers were due on Friday, January 24, 2020. On Friday, I reached out to
defendants'
counsel to inform him that I could resolve the case and close on the subject
property. Given his repeated statemêñts that his clients were eager to do so, I assumed we
would settle and these papers would be uññêcessary. I was shocked when counsel
respcñded and included a new and unacceptable term to settle. By the time I received that
information, late on Friday afternoon, I could not complete and filethese papers.
(Subsequently, over the weekend, I thought I could discontinue the case, but I was
mistaken).
Accordingly, I have filed them on the next business day and ask that they be
accepted by the Court. Given the relationship with counsel, I have not asked his consent.
Res tfully submitted,
yer Y. Silber
by NYSCEF
Document Filed Date
January 27, 2020
Case Filing Date
July 26, 2019
Category
Commercial Division
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THE SILBER LAw FIRM, LLC 11 BROADWAY · SUITE 71S NEW YORK. NEW YORK 10004 TELEPHONE: (212) 76S-4567 MEYERY. 51LBER FACSIMILE: (212) 504-816S MSILBER@$1LBERLAWNY.COM 342 BEDFORD AVENUE DANIELLEL 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 Room 570 - Part 3 Division, 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. I write to ask the Court's indulgence in accepting plaintiff's opposition papers one day later than the parties had agreed. The papers were due on Friday, January 24, 2020. On Friday, I reached out to defendants' counsel to inform him that I could resolve the case and close on the subject property. Given his repeated statemêñts that his clients were eager to do so, I assumed we would settle and these papers would be uññêcessary. I was shocked when counsel respcñded and included a new and unacceptable term to settle. By the time I received that information, late on Friday afternoon, I could not complete and filethese papers. (Subsequently, over the weekend, I thought I could discontinue the case, but I was mistaken). Accordingly, I have filed them on the next business day and ask that they be accepted by the Court. Given the relationship with counsel, I have not asked his consent. Res tfully submitted, yer Y. Silber by NYSCEF