FILED: QUEENS COUNTY CLERK 05/04/2017 01:07 PM INDEX NO.

712807/2016
NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 05/04/2017

SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF QUEENS

KCM REALTY COMPANY, L.P., Index No. 712807/2016

Plaintiff, Justice Leonard Livote

IAS Part 33
v. COMMERCIAL DIVISION
PART A
NEW RAM REALTY, LLC,
NOTICE OF MOTION TO
Defendant. COMPEL DISCLOSURE FROM
DEFENDANT__________

PLEASE TAKE NOTICE that, upon the accompanying Affirmation of Mitchell J. Geller,

dated May 4, 2017, together with the exhibits annexed thereto, the accompanying Memorandum

of Law and the prior pleadings and proceedings herein, Plaintiff KCM Realty Company, L.P., by

its attorneys Holland & Knight LLP, will move this Court in Commercial Division, Part A,

Courtroom 122, at the Courthouse, 88-11 Sutphin Blvd, Jamaica, New York, 11435, on May 23,

2017 at 10:00 A.M. or as soon thereafter as counsel can be heard, for the following relief:

(1) An Order, pursuant to CPLR 3124, to compel Defendant to serve its Response to

Plaintiffs First Notice of Discovery and Inspection, dated December 16, 2016, and to produce

the documents requested by Plaintiffs First Notice of Discovery and Inspection, dated December

16, 2016, as required by the Preliminary Conference Order, dated February 28, 2017;

(2) An Order, pursuant to CPLR 3124, to compel Defendant to serve its Statement of

names and addresses of witnesses and statements of opposing parties, if any, as required by the

Preliminary Conference Order, dated February 28, 2017; and

(3) An Order granting such other and further relief as the Court deems just and

proper.

1 of 2
FILED: QUEENS COUNTY CLERK 05/04/2017 01:07 PM INDEX NO. 712807/2016
NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 05/04/2017

PLEASE TAKE FURTHER NOTICE that pursuant to CPLR 2214(b), answering papers,

if any, shall be served upon the undersigned no less than seven (7) days prior to the return date of

this motion.

Dated: May 4, 2017

New York, New York HOLLAND & KNIGHT LLP

By: A.
Mitchell J. G^lar
31 West 52nd Street
New York, New York 10019
(212) 513-3200

Attorneys for Plaintiff

KCM Realty Company, LP.

TO: VIA NYSCEF

CLIFFORD GREENE & ASSOCIATES
700 White Plains Post Road, Suite 309
Scarsdale, New York 10583
(914) 738-5992
Attn: Clifford H. Greene, Esq.
Attorneys for Defendant New Ram Realty, LLC

#51104935 vl

2 of 2