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Mitchell J. Geller
(212) 513-3483
mitchell.geller@hklaw.com
Re: KCM Realty Company. LLP v. New Ram Realty LLC, Index No. 712807/2016;
Request For Extension Of Time To File Summary Judgment Motion
letter is to request an extension of the time to file a summary judgment motion from October 4.
2018 to October 16, 2018. Defendant's counsel has consented to the extension, but has objected
to the proposed briefing schedule.
By an Order entered on June 27, 2018, this Court extended the time to file summary
judgment motions to October 4. 2018. (A copy of this June 27, 2018 Order is annexed hereto as
Exhibit 1). By e-mails dated September 7 and 11, 2018 to Clifford Greene,-Defendant's counsel,
I requested Defendant's consent to the extension of the time to file summary judgment motions
from October 4 to October 16, 2018. By an e-mail dated September 11, 2018, Mr. Greene stated
time."
that "I don't have a problem extending (A copy of Mr. Greene's September 11, 2018 e-mail
and my September 7 and 11, 2018 e-mails is annexed hereto as Exhibit 2.)
On September 14, .2018, I proposed the following briefing schedule on the summary
judgment motion to Mr. Greene:
Anchorage ] Atlanta | Austin | Boston | Charlotte | Chicago Dallas | Denver Fort Lauderdale | Houston | Jacksonville ] Lakeland
Los Angeles { Miami | New York j Orlando j Portland | San Francisco | Stamford I Tallahassee | Tampa | Tysons
Washington, D.C. | West Palm Beach
Justice Leonard Livote
Page 2
Although Mr. Greene, Defendant's counsel, has agreed to the extension of the time to file
summary judgment motions to October 16, 2018, he does not agree to the proposed briefing
schedule, which Plaintiff believes is very reasonable and affords more than sufficient time to
submit opposing and reply papers on the motion.
Plaintiff respectfully requests a conference call among Kevin Morrissey, your law clerk,
and counsel for the parties as soon as possible to discuss the requested extension and the briefmg
ordered"
schedule in an effort to reach a Stipulation that would be "so by Your Honor.
Respectfully submitted,
Mitchell J. Geller
#60648530 vI
Exhibit 1
NYSCEF DOC, NO. 91
RECEIVED N CEF: 05/01/201E
SEQUENCE No.
)
Plaintiff )
-against- . ) REFEREE
)
Defendant ) DATE
FILED
) SO ORD
MAY 1 • .2018
COUNTYCLERK
. LEONARD UV
·Page 1 fo
Exhibit 2
Mitchell J (NYC -
Geller, X73483)
Mitchel,
I don't have a problem extending time, will get back to tomorrow or Thursday.
Regards,
cliff
................................................................
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Cliff,
1
Please respond to my September 7 e-mail and advise me whether you agree to my proposal of a
Stipulation which extends Plaintiff's date to e-file the summary judgment motion and includes the
mitchell.geller@hklaw.com www.hklaw.com
September 7, 2018
Cliff,
As you may recall, the time for plaintiff to e-file a summary judgment motion was extended to October
4, 2018. I would like to extend that date by a few weeks to October 16, 2018. I thought it would be a
good idea to submit a Stipulation to the Court which extends Plaintiff's date to e-file the summary
judgment motion and includes a briefing schedule satisfactory to you and nie under which defendant
would have additional time to serve opposing papers and plaintiff would have additional time to serve
Please get back to me as soon as possible on my proposal. If you agree, I would like to submit the
ordered"
Stipulation to be "so by next Tuesday or Wednesday.
Mitchell
mitchell.geller@hklaw.com I www.hklaw.com