Kairos Credit Strategies Operating Partnership, LP, v. The Friars National Association, Inc. et al
| KAIROS CREDIT STRATEGIES OPERATING PARTNERSHIP, LP |
| THE FRIARS NATIONAL ASSOCIATION, INC., CITY OF NEW YORK DEPARTMENT OF ENVIRONMENTAL CONTROL, COMMISSIONER OF LABOR STATE OF NEW YORK DEPARTMENT OF LABOR, NEW YORK STATE TAX DEPARTMENT LEGAL DEPARTMENT, NEW YORK CITY FINANCE ADMINISTRATION BUREAU OF COMPLIANCE AND COLLECTION, John Doe #1 through John Doe #20, the twenty names being fictitious and unknown to the Plaintiffs, the person or parties intended being the tenants, occupants, persons or corporations, if an and John Doe #1 through John Doe #20 |
| HOTEL RESTAURANT & CLUB EMPLOYEES AND BARTENDERS UNION LOCAL 6 AND CLUB EMPLOYEES PENSION FUND |
| Kairos Credit Strategies Operating Partnership, LP, |
| 1:2023cv02960 |
| April 7, 2023 |
| US District Court for the Southern District of New York |
| J Paul Oetken |
| Real Property: Foreclosure |
| 28 U.S.C. § 1332 fc Diversity - Foreclosure |
| None |
Docket Report
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This docket was last retrieved on February 9, 2024. A more recent docket listing may be available from PACER.
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Filing 68
NOTICE of Bond of Receiver re: #67 Order,,,. Document filed by Kairos Credit Strategies Operating Partnership, LP,..(Lichtenstein, Mark)
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Filing 67
ORDER APPOINTING RECEIVER: IT IS on this 26th day of May, 2023, ORDERED as follows: Trigild IVL Group, LLC, with offices at 24 Church Street, Montclair, New Jersey 07042, Telephone No. (973) 226-1950, acting through one of its principals, Ian Lagowitz, is appointed as the temporary receiver ("Receiver") of Borrower's Assets (as defined herein). Receiver shall be compensated at the monthly rate of $300 per hour with a minimum of $2,000 for receivership services, reimbursement of all out-of-pocket expenses, and oversight management for $1,500.00 per month, as generally referenced in Exhibit O to the Hu Declaration. This Court shall retain jurisdiction of this action for any proceedings necessary to enforce compliance with this Order. (Signed by Judge J. Paul Oetken on 5/26/2023) (ate)
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Filing 66
OPINION AND ORDER re: #26 EMERGENCY MOTION to Appoint Receiver(s) Trigild IVL Group, LLC . filed by Kairos Credit Strategies Operating Partnership, LP. For the foregoing reasons, Plaintiff's Emergency Motion to Appoint Trigild IVL Group, LLC as Receiver for 57 East 55th Street, New York, New York 10022 is GRANTED. The Clerk of the Court is respectfully directed to close the docket entry at ECF Number 26. (Signed by Judge J. Paul Oetken on 5/26/2023) (ate)
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Filing 65
ANSWER to #1 Complaint,,,. Document filed by The Friars National Association, Inc...(Biolsi, Steven)
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Filing 64
ANSWER to #1 Complaint,,,., CROSSCLAIM against City of New York Department of Environmental Control, Commissioner of Labor State of New York Department of Labor, John Doe #1 through John Doe #20, Kairos Credit Strategies Operating Partnership, LP,, New York City Finance Administration Bureau of Compliance and Collection, New York State Tax Department Legal Department, The Friars National Association, Inc.. Document filed by Hotel Restaurant & Club Employees and Bartenders Union Local 6 and Club Employees Pension Fund. (Attachments: #1 Exhibit A - CBA, #2 Exhibit B - MOAs, #3 Exhibit C - Judgment).(Hanrahan, Trevor)
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Filing 63
RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Hotel Restaurant & Club Employees and Bartenders Union Local 6 and Club Employees Pension Fund..(Hanrahan, Trevor)
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Filing 62
RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Hotel Restaurant & Club Employees and Bartenders Union Local 6 and Club Employees Pension Fund..(Hanrahan, Trevor)
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Filing 61
ORDER: Counsel for the parties shall appear for a telephone conference on May 23, 2023, at 11:00 AM New York Time. At the scheduled time, counsel should call (888) 557-8511 at the scheduled time. The access code is 9300838. SO ORDERED. (HEREBY ORDERED by Judge J. Paul Oetken) (Text Only Order) (jhk)
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Filing 60
ORDER granting #58 Letter Motion for Leave to File Document: SO ORDERED. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (jhk)
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Filing 59
DECLARATION of Arthur Aidala in Opposition re: #26 EMERGENCY MOTION to Appoint Receiver(s) Trigild IVL Group, LLC ., #58 FIRST LETTER MOTION for Leave to File Amended Reply Declaration Correcting the word "Plaintiff" with "Defendant" at paragraph 5 addressed to Judge J. Paul Oetken from Steven Alexander Biolsi dated 05/17/2023.. Document filed by The Friars National Association, Inc.. (Attachments: #1 Exhibit A - Email From Defendant's Insurance Company Account Executive, #2 Exhibit B - Property Insurance Policy, #3 Exhibit C - Additional Property Insurance Policy Documents, #4 Exhibit D - Liability Policy Documents).(Biolsi, Steven)
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Filing 58
FIRST LETTER MOTION for Leave to File Amended Reply Declaration Correcting the word "Plaintiff" with "Defendant" at paragraph 5 addressed to Judge J. Paul Oetken from Steven Alexander Biolsi dated 05/17/2023. Document filed by The Friars National Association, Inc...(Biolsi, Steven)
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***NOTICE TO ATTORNEY REGARDING DEFICIENT RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Notice to Attorney Barry Neal Saltzman to RE-FILE Document No. #53 Rule 7.1 Corporate Disclosure Statement, #54 Rule 7.1 Corporate Disclosure Statement,. The filing is deficient for the following reason(s): the jurisdiction of this action is based on diversity - the party/intervenor did not name and identify the citizenship of every individual or entity whose citizenship is attributed to that party or intervenor. Re-file the document using the event type Rule 7.1 Corporate Disclosure Statement found under the event list Other Documents - select the correct filer/filers - attach the correct signed PDF - when prompted with the message "Are there any corporate parents or other affiliates?", select the Yes or No radio button - If Yes - enter the corporate parent/other affiliate, click the Search button - select the correct corporate parent/other affiliate name from the search results list or if no person found, create a new corporate parent/other affiliate - select the party to whom the corporate parent/other affiliate should be linked - add corporate parent/other affiliate names one at a time - name and identify the citizenship of every individual or entity whose citizenship is attributed to that party or intervenor. Please use the revised form found here # NYSD form page (lb)
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Filing 57
DECLARATION of Arthur Aidala in Opposition re: #26 EMERGENCY MOTION to Appoint Receiver(s) Trigild IVL Group, LLC .. Document filed by The Friars National Association, Inc.. (Attachments: #1 Exhibit A - Email From Insurance Company Account Executive, #2 Exhibit B - Property Insurance Policy, #3 Exhibit C - Additional Property Insurance Policy Documents, #4 Exhibit D - Liability Policy Document).(Biolsi, Steven)
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Filing 56
MEMORANDUM OF LAW in Opposition re: #26 EMERGENCY MOTION to Appoint Receiver(s) Trigild IVL Group, LLC . . Document filed by Hotel Restaurant & Club Employees and Bartenders Union Local 6 and Club Employees Pension Fund..(Saltzman, Barry)
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Filing 55
DECLARATION of Alyssa Tramposch in Opposition re: #26 EMERGENCY MOTION to Appoint Receiver(s) Trigild IVL Group, LLC .. Document filed by Hotel Restaurant & Club Employees and Bartenders Union Local 6 and Club Employees Pension Fund. (Attachments: #1 Exhibit A-CBA, #2 Exhibit B-IWA, #3 Exhibit C-Judgment, #4 Exhibit D-Order Confirming Arbitration Award, #5 Exhibit E-Arbitration Award, #6 Exhibit F-Examples of Activities in Prior Labor Disputes).(Saltzman, Barry)
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Filing 54
FILING ERROR -- DEFICIENT DOCKET ENTRY - MISSING DIVERSITY INFORMATION -SECOND RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Hotel Restaurant & Club Employees and Bartenders Union Local 6 and Club Employees Pension Fund..(Saltzman, Barry) Modified on 5/17/2023 (lb).
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Filing 53
FILING ERROR -- DEFICIENT DOCKET ENTRY - MISSING DIVERSITY INFORMATION -FIRST RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Hotel Restaurant & Club Employees and Bartenders Union Local 6 and Club Employees Pension Fund..(Saltzman, Barry) Modified on 5/17/2023 (lb).
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Filing 52
ORDER granting #51 Letter Motion for Extension of Time to File Response/Reply: Defendant's 1-day extension request is GRANTED. The Court's order at ECF No. 50 is therefore extended by 1 day, and Defendant shall file any responsive papers by 5:00 PM New York Time tomorrow, May 16, 2023. SO ORDERED. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (jhk)
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Filing 51
FIRST LETTER MOTION for Extension of Time to File Response/Reply as to 50 Order, #49 Reply Affirmation in Support of Motion addressed to Judge J. Paul Oetken from Steven Alexander Biolsi dated 05/15/2013. Document filed by The Friars National Association, Inc...(Biolsi, Steven)
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Filing 50
ORDER: Friar's National should file its opposition, if any, to Plaintiff's Reply Affirmation of Raymond Hu dated May 10, 2023, (ECF No. 49) on or before May 15, 2023. SO ORDERED. (HEREBY ORDERED by Judge J. Paul Oetken) (Text Only Order) (jhk)
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Filing 49
REPLY AFFIRMATION of Raymond Hu in Support re: #26 EMERGENCY MOTION to Appoint Receiver(s) Trigild IVL Group, LLC .. Document filed by Kairos Credit Strategies Operating Partnership, LP,..(Lichtenstein, Mark)
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Filing 48
NOTICE OF APPEARANCE by Trevor Hanrahan on behalf of Hotel Restaurant & Club Employees and Bartenders Union Local 6 and Club Employees Pension Fund..(Hanrahan, Trevor)
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Filing 47
ORDER: #46 Letter Motion for Extension of Time to Answer is GRANTED. Defendants shall move, answer, or otherwise respond to the Complaint on or before May 19, 2023. SO ORDERED. (HEREBY ORDERED by Judge J. Paul Oetken)(Text Only Order) (jhk)
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Minute Entry for proceedings held before Judge J. Paul Oetken: Oral Argument held on 5/5/2023 re: #26 EMERGENCY MOTION to Appoint Receiver(s). Decision reserved. (bh)
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Filing 46
LETTER MOTION for Extension of Time to File Answer re: #1 Complaint,,, addressed to Judge J. Paul Oetken from Barry N. Saltzman dated May 4, 2023. Document filed by Hotel Restaurant & Club Employees and Bartenders Union Local 6 and Club Employees Pension Fund..(Saltzman, Barry)
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Filing 45
MEMO ENDORSEMENT on re: #42 Letter, filed by Kairos Credit Strategies Operating Partnership, LP. ENDORSEMENT: Given the declarations already filed electronically, the Court does not currently believe it to be necessary to hear live testimony at the May 5, 2023 hearing. (See ECF No. 43.) However, if the parties deem it important and relevant that the Court hear live testimony, they should be prepared to present witnesses at that time. SO ORDERED. (Signed by Judge J. Paul Oetken on 5/3/2023) (tg)
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Filing 44
REPLY MEMORANDUM OF LAW in Support re: #26 EMERGENCY MOTION to Appoint Receiver(s) Trigild IVL Group, LLC . . Document filed by Kairos Credit Strategies Operating Partnership, LP,..(Lichtenstein, Mark)
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Filing 43
REPLY AFFIRMATION of Raymond Hu in Support re: #26 EMERGENCY MOTION to Appoint Receiver(s) Trigild IVL Group, LLC .. Document filed by Kairos Credit Strategies Operating Partnership, LP,. (Attachments: #1 Exhibit A -April 26, 2023 Article).(Lichtenstein, Mark)
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Filing 42
LETTER addressed to Judge J. Paul Oetken from Mark S. Lichtenstein on behalf of Plaintiff dated April 28, 2023 re: ascertain if May 5, 2023 Show Cause Hearing wil be an evidentiary hearing. Document filed by Kairos Credit Strategies Operating Partnership, LP,..(Lichtenstein, Mark)
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Filing 41
ACKNOWLEDGMENT OF SERVICE Summons and Complaint,,, served. New York State Tax Department Legal Department served on 4/14/2023, answer due 5/5/2023. Service was accepted by Bridgett McCarthy, TIA. Document filed by Kairos Credit Strategies Operating Partnership, LP,..(Lichtenstein, Mark)
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Filing 40
ACKNOWLEDGMENT OF SERVICE Summons and Complaint,,, served. Commissioner of Labor State of New York Department of Labor served on 4/14/2023, answer due 5/5/2023. Service was accepted by Debra Collura, Senior Attorney. Document filed by Kairos Credit Strategies Operating Partnership, LP,..(Lichtenstein, Mark)
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Filing 39
ACKNOWLEDGMENT OF SERVICE Summons and Complaint,,, served. Service was accepted by Michael Stamp, External Affairs. Document filed by Kairos Credit Strategies Operating Partnership, LP,..(Lichtenstein, Mark)
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Filing 38
ACKNOWLEDGMENT OF SERVICE Summons and Complaint,,, served. New York City Finance Administration Bureau of Compliance and Collection served on 4/12/2023, answer due 5/3/2023. Service was accepted by S. Holmes, Mailroom Clerk. Document filed by Kairos Credit Strategies Operating Partnership, LP,..(Lichtenstein, Mark)
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Filing 37
ACKNOWLEDGMENT OF SERVICE Summons and Complaint,,, served. City of New York Department of Environmental Control served on 4/13/2023, answer due 5/4/2023. Service was accepted by Ariton Marke, Deputy Unit Chief. Document filed by Kairos Credit Strategies Operating Partnership, LP,..(Lichtenstein, Mark)
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Filing 36
MEMORANDUM OF LAW in Opposition re: #26 EMERGENCY MOTION to Appoint Receiver(s) Trigild IVL Group, LLC . . Document filed by The Friars National Association, Inc.. (Attachments: #1 Affidavit Declaration In Opposition By Steven Alexander Biolsi, #2 Affidavit Declaration In Opposition By Arthur Aidala, President Of Defendant, #3 Exhibit A - Photographs Taken 4/25/2023 Of Subject Property, #4 Exhibit B - Real Estate Broker's Agreement).(Biolsi, Steven)
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Filing 35
AFFIDAVIT OF SERVICE of Summons and Complaint served on HOTEL RESTAURANT & CLUB EMPLOYEES AND BARTENDERS UNION LOCAL 6 AND CLUB EMPLOYEES PENSION FUND on 04/12/2023. Service was accepted by DeShawn Belton, Legal Administrator. Document filed by Kairos Credit Strategies Operating Partnership, LP,..(Lichtenstein, Mark)
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Filing 34
RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by The Friars National Association, Inc...(Biolsi, Steven)
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Filing 33
NOTICE OF APPEARANCE by Steven Alexander Biolsi on behalf of The Friars National Association, Inc...(Biolsi, Steven)
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Filing 32
RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Other Affiliate Kairos Credit Strategies REIT, Inc., Other Affiliate Kairos Incentive Company, LLC, Other Affiliate CIPC, LLC, Other Affiliate Chang Family Partners, LP, Other Affiliate Ly Enterprises, Inc., Other Affiliate CMCB Enterprise, Inc., Other Affiliate Michael TP Chang, Inc., Other Affiliate Michael TP Chang, Other Affiliate Carl JP Chang, Other Affiliate Joe HS Chang, Other Affiliate Betty LY Chang, Other Affiliate Solid Rock Commercial, LLC, Other Affiliate Diana Chang, Other Affiliate Jonathan A Needell for Kairos Credit Strategies Operating Partnership, LP,. Document filed by Kairos Credit Strategies Operating Partnership, LP,..(Lichtenstein, Mark)
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Filing 31
NOTICE of Notice of Filing of Notice of Pendency of Action re: #1 Complaint,,,. Document filed by Kairos Credit Strategies Operating Partnership, LP,..(Lichtenstein, Mark)
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Filing 30
AFFIDAVIT OF SERVICE of (i) Order to Show Cause; (ii) Memorandum of Law in Support of Motion to Appoint Receiver and (iii) Declarations in Support of Motion to Appoint Receiver served on The Friars National Association, Inc., City of New York Department of Environmental Control, Commissioner of Labor State of New York Department of Labor, New York State Tax Department Legal Department, New York City Finance Administration Bureau of Compliance and Collection and Hotel, Restaurant & Club Employees and Bartenders Union Local 6 and Club Employees' Pension Fund on April 14, 2023. Service was made by Federal Express. Document filed by Kairos Credit Strategies Operating Partnership, LP,..(Lichtenstein, Mark)
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Filing 29
ORDER TO SHOW CAUSE. It is hereby: ORDERED that the above-named defendants, either in person or by their attorneys, show cause before this Court at Courtroom 706, Thurgood Marshall United States Courthouse, 40 Foley Square, New York, New York, on Friday, May 5, 2023, at 2:00 p.m. why this Court should not enter an Order: (i) granting the appointment of a receiver for Borrowers interest in the Mortgaged Premises, along with the buildings, structures, fixtures, and other improvements now or hereafter located on the Mortgaged Premises, as well as the Land, Improvements, Equipment, Rents, Leases, Personal Property, Licenses and Permits, and other collateral granted by the Mortgage; and (ii) granting such other and further relief as the Court deems just and proper in these circumstances. Plaintiff shall serve a copy of this Order together with the papers upon which it is granted, upon each of the above-named defendants by April 17, 2023; and Counsel for Defendants shall file appearances on ECF by April 21, 2023. Any opposition to the application of Plaintiff brought on by this Order to Show Cause shall be filed on ECF and served upon Plaintiff by email to counsel of record for Plaintiff, Akerman LLP, on or before April 26, 2023; and any reply to the opposition shall be filed on ECF by May 2, 2023. SO ORDERED. ( Show Cause Hearing set for 5/5/2023 at 02:00 PM in Courtroom 706, 40 Centre Street, New York, NY 10007 before Judge J. Paul Oetken. Show Cause Response due by 4/26/2023.) (Signed by Judge J. Paul Oetken on 4/12/23) (yv)
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Filing 28
DECLARATION of Mark S. Lichtenstein in Support re: #26 EMERGENCY MOTION to Appoint Receiver(s) Trigild IVL Group, LLC .. Document filed by Kairos Credit Strategies Operating Partnership, LP,..(Lichtenstein, Mark)
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Filing 27
DECLARATION of Raymond Hu a/k/a Zilong Hu in Support re: #26 EMERGENCY MOTION to Appoint Receiver(s) Trigild IVL Group, LLC .. Document filed by Kairos Credit Strategies Operating Partnership, LP,..(Lichtenstein, Mark)
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Filing 26
EMERGENCY MOTION to Appoint Receiver(s) Trigild IVL Group, LLC . Document filed by Kairos Credit Strategies Operating Partnership, LP,..(Lichtenstein, Mark)
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***NOTICE TO ATTORNEY TO RE-FILE DOCUMENT - EVENT TYPE ERROR. Notice to Attorney Mark S. Lichtenstein to RE-FILE Document #4 MOTION to Appoint Temporary Receiver by Memorandum of Law in Support.. Use the event type Replies, Opposition and Supporting Documents found under the event list Memorandum of Law in Support to Motion. ***REMINDER***MOTION WAS NOT FILED. FIRST FILE THE MOTION, THEN LINK THE SUPPORTING DOCUMENT(S) TO THE MOTION.*** (kj)
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***NOTICE TO ATTORNEY TO RE-FILE DOCUMENT - DEFICIENT DOCKET ENTRY ERROR. Notice to Attorney Mark S. Lichtenstein to RE-FILE Document #5 Declaration in Support of Motion,. ERROR(S): Incomplete Document (i.e.,No signature or s/).. (kj)
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***NOTICE TO ATTORNEY TO RE-FILE DOCUMENT - DEFICIENT DOCKET ENTRY ERROR. Notice to Attorney Mark S. Lichtenstein to RE-FILE Document #9 Declaration in Support of Motion, #6 Declaration in Support of Motion,. ERROR(S): Supporting document(s) was linked to a deficient filing. (kj)
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Filing 25
FILING ERROR - DEFICIENT DOCKET ENTRY - MISSING DIVERSITY INFORMATION - RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Other Affiliate Kairos Credit Strategies REIT, Inc., a Delaware Corporation, Other Affiliate Kairos Incentive Company, LLC, a Delaware limited liability comapny for Kairos Credit Strategies Operating Partnership, LP,. Document filed by Kairos Credit Strategies Operating Partnership, LP,..(Lichtenstein, Mark) Modified on 4/10/2023 (kw).
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Filing 24
CIVIL COVER SHEET filed..(Lichtenstein, Mark)
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Filing 23
ELECTRONIC SUMMONS ISSUED as to New York City Finance Administration Bureau of Compliance and Collection..(pc)
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Filing 22
ELECTRONIC SUMMONS ISSUED as to City of New York Department of Environmental Control..(pc)
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Filing 21
ELECTRONIC SUMMONS ISSUED as to Hotel Restaurant & Club Employees and Bartenders Union Local 6 and Club Employees Pension Fund..(pc)
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Filing 20
ELECTRONIC SUMMONS ISSUED as to Commissioner of Labor State of New York Department of Labor..(pc)
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Filing 19
ELECTRONIC SUMMONS ISSUED as to New York State Tax Department Legal Department..(pc)
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Filing 18
ELECTRONIC SUMMONS ISSUED as to New York City Finance Administration Bureau of Compliance and Collection..(pc)
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Filing 17
ELECTRONIC SUMMONS ISSUED as to The Friars National Association, Inc...(pc)
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***NOTICE TO ATTORNEY REGARDING PARTY MODIFICATION. Notice to attorney Mark S. Lichtenstein. The party information for the following party/parties has been modified: KAIROS CREDIT STRATEGIES OPERATING PARTNERSHIP, LP, THE FRIARS NATIONAL ASSOCIATION, INC., CITY OF NEW YORK DEPARTMENT OF ENVIRONMENTAL CONTROL, COMMISSIONER OF LABOR STATE OF NEW YORK DEPARTMENT OF LABOR, NEW YORK STATE TAX DEPARTMENT LEGAL DEPARTMENT, NEW YORK CITY FINANCE ADMINISTRATION BUREAU OF COMPLIANCE AND COLLECTION, HOTEL RESTAURANT & CLUB EMPLOYEES AND BARTENDERS UNION LOCAL 6 AND CLUB EMPLOYEES PENSION FUND, John Doe #1 through John Doe #20, the twenty names being fictitious and unknown to the Plaintiffs, the person or parties intended being the tenants, occupants, persons or corporations, if an. The information for the party/parties has been modified for the following reason/reasons: party name was entered in all caps; party text was omitted; DO NOT TYPE ALL PARTY NAMES IN ALL CAPS. (pc)
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Case Designated ECF. (pc)
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Magistrate Judge Jennifer Willis is so designated. Pursuant to 28 U.S.C. Section 636(c) and Fed. R. Civ. P. 73(b)(1) parties are notified that they may consent to proceed before a United States Magistrate Judge. Parties who wish to consent may access the necessary form at the following link: #https://nysd.uscourts.gov/sites/default/files/2018-06/AO-3.pdf. (pc)
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***NOTICE TO ATTORNEY REGARDING CIVIL. CASE OPENING STATISTICAL ERROR CORRECTION: Notice to attorney Mark S. Lichtenstein. The following case opening statistical information was erroneously selected/entered: County code New York;. The following correction(s) have been made to your case entry: the County code has been modified to XX Out of State;. (pc)
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CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge J. Paul Oetken. Please download and review the Individual Practices of the assigned District Judge, located at #https://nysd.uscourts.gov/judges/district-judges. Attorneys are responsible for providing courtesy copies to judges where their Individual Practices require such. Please download and review the ECF Rules and Instructions, located at #https://nysd.uscourts.gov/rules/ecf-related-instructions..(pc)
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***NOTICE TO ATTORNEY REGARDING DEFICIENT PLEADING. Notice to Attorney Mark S. Lichtenstein to RE-FILE Document No. #1 Complaint,,,. The filing is deficient for the following reason(s): the All Defendant radio button was selected;. Re-file the pleading using the event type Complaint found under the event list Complaints and Other Initiating Documents - attach the correct signed PDF - select the individually named filer/filers - select the individually named party/parties the pleading is against. (pc)
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***NOTICE TO ATTORNEY REGARDING DEFICIENT RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Notice to Attorney Mark S. Lichtenstein to RE-FILE Document No. #25 Rule 7.1 Corporate Disclosure Statement,. The filing is deficient for the following reason(s): the jurisdiction of this action is based on diversity - the party/intervenor did not name and identify the citizenship of every individual or entity whose citizenship is attributed to that party or intervenor. Re-file the document using the event type Rule 7.1 Corporate Disclosure Statement found under the event list Other Documents - select the correct filer/filers - attach the correct signed PDF - when prompted with the message "Are there any corporate parents or other affiliates?", select the Yes radio button - enter the corporate parent/other affiliate, click the Search button - select the correct corporate parent/other affiliate name from the search results list or if no person found, create a new corporate parent/other affiliate - select the party to whom the corporate parent/other affiliate should be linked - add corporate parent/other affiliate names one at a time - name and identify the citizenship of every individual or entity whose citizenship is attributed to that party or intervenor. (kw)
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***NOTICE TO COURT REGARDING PROPOSED ORDER. Document No. #8 Proposed Order was reviewed and approved as to form. (km)
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***NOTICE TO ATTORNEY REGARDING DEFICIENT RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Notice to Attorney Mark S. Lichtenstein to RE-FILE Document No. #3 Rule 7.1 Corporate Disclosure Statement,. The filing is deficient for the following reason(s): the jurisdiction of this action is based on diversity - the party/intervenor did not name and identify the citizenship of every individual or entity whose citizenship is attributed to that party or intervenor. Re-file the document using the event type Rule 7.1 Corporate Disclosure Statement found under the event list Other Documents - select the correct filer/filers - attach the correct signed PDF - when prompted with the message "Are there any corporate parents or other affiliates?", select the Yes radio button - enter the corporate parent/other affiliate, click the Search button - select the correct corporate parent/other affiliate name from the search results list or if no person found, create a new corporate parent/other affiliate - select the party to whom the corporate parent/other affiliate should be linked - add corporate parent/other affiliate names one at a time - name and identify the citizenship of every individual or entity whose citizenship is attributed to that party or intervenor. (kw)
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***NOTICE TO COURT REGARDING PROPOSED ORDER TO SHOW CAUSE WITH EMERGENCY RELIEF. Document No. #7 Proposed Order to Show Cause With Emergency Relief was reviewed and approved as to form. (km)
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***NOTICE TO ATTORNEY REGARDING DEFICIENT CIVIL COVER SHEET. Notice to attorney Mark S. Lichtenstein to RE-FILE Document No. #2 Civil Cover Sheet. The filing is deficient for the following reason(s): multiple citizenships for the plaintiff and the first listed defendant were selected. Choose one;. Re-file the document using the event type Civil Cover Sheet found under the event list Other Documents and attach the correct PDF. (pc)
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Filing 16
REQUEST FOR ISSUANCE OF SUMMONS as to HOTEL RESTAURANT & CLUB EMPLOYEES AND BARTENDERS UNION LOCAL 6 AND CLUB EMPLOYEES PENSION FUND, re: #1 Complaint,,. Document filed by KAIROS CREDIT STRATEGIES OPERATING PARTNERSHIP, LP..(Lichtenstein, Mark)
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Filing 15
REQUEST FOR ISSUANCE OF SUMMONS as to NEW YORK CITY FINANCE ADMINISTRATION BUREAU OF COMPLIANCE AND COLLECTION, re: #1 Complaint,,. Document filed by KAIROS CREDIT STRATEGIES OPERATING PARTNERSHIP, LP..(Lichtenstein, Mark)
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Filing 14
REQUEST FOR ISSUANCE OF SUMMONS as to NEW YORK CITY FINANCE ADMINISTRATION BUREAU OF COMPLIANCE AND COLLECTION, re: #1 Complaint,,. Document filed by KAIROS CREDIT STRATEGIES OPERATING PARTNERSHIP, LP..(Lichtenstein, Mark)
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Filing 13
REQUEST FOR ISSUANCE OF SUMMONS as to NEW YORK STATE TAX DEPARTMENT LEGAL DEPARTMENT, re: #1 Complaint,,. Document filed by KAIROS CREDIT STRATEGIES OPERATING PARTNERSHIP, LP..(Lichtenstein, Mark)
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Filing 12
REQUEST FOR ISSUANCE OF SUMMONS as to COMMISSIONER OF LABOR STATE OF NEW YORK DEPARTMENT OF LABOR, re: #1 Complaint,,. Document filed by KAIROS CREDIT STRATEGIES OPERATING PARTNERSHIP, LP..(Lichtenstein, Mark)
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Filing 11
REQUEST FOR ISSUANCE OF SUMMONS as to CITY OF NEW YORK DEPARTMENT OF ENVIRONMETNAL CONTROL, re: #1 Complaint,,. Document filed by KAIROS CREDIT STRATEGIES OPERATING PARTNERSHIP, LP..(Lichtenstein, Mark)
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Filing 10
REQUEST FOR ISSUANCE OF SUMMONS as to THE FRIARS NATIONAL ASSOCIATION, INC., re: #1 Complaint,,. Document filed by KAIROS CREDIT STRATEGIES OPERATING PARTNERSHIP, LP..(Lichtenstein, Mark)
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Filing 9
FILING ERROR - DEFICIENT DOCKET ENTRY - DECLARATION of RAYMOND HU A/K/A ZILONG HU in Support re: #4 MOTION to Appoint Temporary Receiver by Memorandum of Law in Support.. Document filed by KAIROS CREDIT STRATEGIES OPERATING PARTNERSHIP, LP..(Lichtenstein, Mark) Modified on 4/12/2023 (kj).
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Filing 8
PROPOSED ORDER. Document filed by KAIROS CREDIT STRATEGIES OPERATING PARTNERSHIP, LP. Related Document Number: #4 ..(Lichtenstein, Mark) Proposed Order to be reviewed by Clerk's Office staff.
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Filing 7
PROPOSED ORDER TO SHOW CAUSE WITH EMERGENCY RELIEF. Document filed by KAIROS CREDIT STRATEGIES OPERATING PARTNERSHIP, LP. Related Document Number: #4 ..(Lichtenstein, Mark) Proposed Order to Show Cause to be reviewed by Clerk's Office staff.
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Filing 6
FILING ERROR - DEFICIENT DOCKET ENTRY - DECLARATION of MARK S. LICHTENSTEIN in Support re: #4 MOTION to Appoint Temporary Receiver by Memorandum of Law in Support.. Document filed by KAIROS CREDIT STRATEGIES OPERATING PARTNERSHIP, LP..(Lichtenstein, Mark) Modified on 4/12/2023 (kj).
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Filing 5
FILING ERROR - DEFICIENT DOCKET ENTRY - SIGNATURE ERROR - DECLARATION of RAYMOND HU A/K/A ZILONG HU in Support re: #4 MOTION to Appoint Temporary Receiver by Memorandum of Law in Support.. Document filed by KAIROS CREDIT STRATEGIES OPERATING PARTNERSHIP, LP..(Lichtenstein, Mark) Modified on 4/12/2023 (kj).
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Filing 4
FILING ERROR - WRONG EVENT TYPE SELECTED FROM MENU - MOTION to Appoint Temporary Receiver by Memorandum of Law in Support. Document filed by KAIROS CREDIT STRATEGIES OPERATING PARTNERSHIP, LP..(Lichtenstein, Mark) Modified on 4/12/2023 (kj).
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Filing 3
FILING ERROR - DEFICIENT DOCKET ENTRY - MISSING DIVERSITY INFORMATION - RULE 7.1 CORPORATE DISCLOSURE STATEMENT. Identifying Other Affiliate Kairos Credit Strategies REIT, Inc., Other Affiliate Kairos Incentive Company, LLC for KAIROS CREDIT STRATEGIES OPERATING PARTNERSHIP, LP. Document filed by KAIROS CREDIT STRATEGIES OPERATING PARTNERSHIP, LP..(Lichtenstein, Mark) Modified on 4/10/2023 (kw).
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Filing 2
FILING ERROR - PDF ERROR - CIVIL COVER SHEET filed..(Lichtenstein, Mark) Modified on 4/10/2023 (pc).
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Filing 1
FILING ERROR - DEFICIENT DOCKET ENTRY - FILED AGAINST PARTY ERROR - COMPLAINT against All Defendants. (Filing Fee $ 402.00, Receipt Number ANYSDC-27580391)Document filed by KAIROS CREDIT STRATEGIES OPERATING PARTNERSHIP, LP. (Attachments: #1 Exhibit A - Original Mortgage, #2 Exhibit B - Allonge, #3 Exhibit C - Assignment of Mortgage, #4 Exhibit D - Loan Agreement, #5 Exhibit E - Gap Note, #6 Exhibit F - Gap Mortgage, #7 Exhibit G - Note, #8 Exhibit H - Mortgage, #9 Exhibit I - Assignment of Leases, #10 Exhibit J - CMA, #11 Exhibit K - State UCC, #12 Exhibit L - City UCC, #13 Exhibit M - Loan Default Notices, #14 Exhibit N - Inspection, #15 Exhibit O - Judgments).(Lichtenstein, Mark) Modified on 4/10/2023 (pc).
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| Search for this case: Kairos Credit Strategies Operating Partnership, LP, v. The Friars National Association, Inc. et al | |
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| Plaintiff: KAIROS CREDIT STRATEGIES OPERATING PARTNERSHIP, LP | |
| Represented By: | Mark S. Lichtenstein |
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| Defendant: THE FRIARS NATIONAL ASSOCIATION, INC. | |
| Represented By: | Steven Alexander Biolsi |
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| Defendant: CITY OF NEW YORK DEPARTMENT OF ENVIRONMENTAL CONTROL | |
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| Defendant: COMMISSIONER OF LABOR STATE OF NEW YORK DEPARTMENT OF LABOR | |
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| Defendant: NEW YORK STATE TAX DEPARTMENT LEGAL DEPARTMENT | |
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| Defendant: NEW YORK CITY FINANCE ADMINISTRATION BUREAU OF COMPLIANCE AND COLLECTION | |
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| Defendant: John Doe #1 through John Doe #20, the twenty names being fictitious and unknown to the Plaintiffs, the person or parties intended being the tenants, occupants, persons or corporations, if an | |
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| Defendant: John Doe #1 through John Doe #20 | |
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| Cross claimant: HOTEL RESTAURANT & CLUB EMPLOYEES AND BARTENDERS UNION LOCAL 6 AND CLUB EMPLOYEES PENSION FUND | |
| Represented By: | Barry Neal Saltzman |
| Represented By: | Trevor Hanrahan |
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| Cross defendant: Kairos Credit Strategies Operating Partnership, LP, | |
| Represented By: | Mark S. Lichtenstein |
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