CLIFFORD H.

GREENE & ASSOCIATES

ATTORNEY AT LAW
700 Post Road, Suite 309
Smrsdale,NY 10583-5032
E-Mail:ditifa>c/wandassonates.aun

(914)472-5992
(914) 738-5992
(914) 725-6160 Fax

STEVE I. LUBOWITZ
MariaE.Valente,Paralegal SCOTT STONE
ARIELLA COLMAN
EMILE SAYEGH
of Counre/

September 18, 2018

SENT VIA EFILE & VIA FACSMILE TRANSMISSION

The Honorable Justice Leonard Livote

Supreme Court, Queens County
Commercial Division part 33, Courtroom 122
88-11 Sutphin Blvd.

Jamaica, New York 11435

Re: KCM Realty Company vs. New Ram Realty, LLC

Index No. 712807/2016

Your Honor,

My office represents the defendant in this matter. This letter is being sent in response to

my adversary's letter dated September 17, 2018. My adversary is seeking an extension of time
to serve and file a motion for summary judgment. I advised my adversary, as he in fact informed
this honorable court, that I would be happy to consent to extend the time for either party to serve
and file a summary judgment motion, however I suggested to my adversary a briefing schedule
that he doesn't agree to. My adversary conveniently failed to mention this and continues to
suggest a briefing scheduled which in my opinion will not be sufficient enough time based upon
the matter at hand. While my adversary has not been completely forthright with the court as to
the extent of our communications on this subject, I would simply request that the court, as did

my adversary, schedule this matter for a conference call or conference to discuss the issues.
 Re tted,

. 1 ford H.

CHG\me
CC: Holland & Knight
Attorneys for Plaintiff
(Sent Via E-file)