On February 07, 2020 a
Motion-Secondary
was filed
involving a dispute between
11 Um Food Corp.,
Urban Fresh Corp.,
Young S. Chung,
and
Barbara Janus,
Colin K. Xie,
Does 1 100,
Juicebrothers, Llc,
for Commercial Division
in the District Court of Kings County.
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FILED: KINGS COUNTY CLERK 07/01/2020 06:59 PM INDEX NO. 503139/2020
NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 07/01/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
----------------------------------------------------------------------- x
YOUNG S. CHUNG, individually and on behalf of :
URBAN FRESH CORP. and 11 UM FOOD CORP. : Index No. 503139/2020
:
Plaintiffs, :
:
-against- :
:
COLIN K. XIE, BARBARA JANUS, :
JUICEBROTHERS, LLC, AND DOES 1-100 :
:
Defendants. :
----------------------------------------------------------------------- x
Motion for Extension of Time to File Responsive Pleading
The Defendants, Barbara Janus and JuiceBrothers, LLC (collectively, “Defendants”),
through their attorneys, moves this Honorable Court for an Order extending the following
deadlines and in support thereof, would show the Court as follows:
1. The Plaintiffs, Young. S. Chung, individually and on behalf of Urban Fresh Corp. and 11
UM Food Corp. (collectively, “Plaintiffs”), filed its Amended Verified Complaint (the
“Complaint”) in the Supreme Court of the State of New York, County of Kings, on May
27, 2020.
2. Defendants were served on or about June 10, 2020, making its answer due on July 1, 2020.
3. The undersigned counsel was recently retained to defend the Defendants.
4. Defendants respectfully request a 30-day extension of time to answer or otherwise respond
to the Complaint, making their responsive pleading due on or before July 30, 2020.
5. This request is being made as counsel for the Defendants and counsel for the Plaintiffs
exchange information in the hopes of resolving this matter without further intervention
from the Court.
1 of 2
FILED: KINGS COUNTY CLERK 07/01/2020 06:59 PM INDEX NO. 503139/2020
NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 07/01/2020
6. Plaintiffs have indicated that they are not opposed to the Defendants receiving an additional
fourteen (14) days to file its responsive pleading. However, Defendants believe that an
additional thirty (30) days is appropriate to allow the parties to continue their exchange of
information and allow Defendants time to prepare a responsive pleading if necessary.
7. This request is made in good faith and is not being made for purposes of delay. This is the
Defendants’ first request for an extension of time to respond to the Complaint.
8. Accordingly, Defendants request an additional thirty (30) days, up to and including July
30, 2020, to file their responsive pleading.
Wherefore, Defendants move for entry of an order providing them to and through July 30, 2020 to
file their responsive pleading, and any other relief this Court deems just and proper.
Dated: New York, New York
July 1, 2020
Respectfully Submitted,
Vivek Jayaram, Esq.
Jayaram Law, Inc.
142 West 57th Street
11th Floor
New York, NY 10019
vivek@jayaramlaw.com
T: 646.325.9855
2 of 2
Document Filed Date
July 01, 2020
Case Filing Date
February 07, 2020
Category
Commercial Division
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FILED: KINGS COUNTY CLERK 07/01/2020 06:59 PM INDEX NO. 503139/2020 NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 07/01/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ----------------------------------------------------------------------- x YOUNG S. CHUNG, individually and on behalf of : URBAN FRESH CORP. and 11 UM FOOD CORP. : Index No. 503139/2020 : Plaintiffs, : : -against- : : COLIN K. XIE, BARBARA JANUS, : JUICEBROTHERS, LLC, AND DOES 1-100 : : Defendants. : ----------------------------------------------------------------------- x Motion for Extension of Time to File Responsive Pleading The Defendants, Barbara Janus and JuiceBrothers, LLC (collectively, “Defendants”), through their attorneys, moves this Honorable Court for an Order extending the following deadlines and in support thereof, would show the Court as follows: 1. The Plaintiffs, Young. S. Chung, individually and on behalf of Urban Fresh Corp. and 11 UM Food Corp. (collectively, “Plaintiffs”), filed its Amended Verified Complaint (the “Complaint”) in the Supreme Court of the State of New York, County of Kings, on May 27, 2020. 2. Defendants were served on or about June 10, 2020, making its answer due on July 1, 2020. 3. The undersigned counsel was recently retained to defend the Defendants. 4. Defendants respectfully request a 30-day extension of time to answer or otherwise respond to the Complaint, making their responsive pleading due on or before July 30, 2020. 5. This request is being made as counsel for the Defendants and counsel for the Plaintiffs exchange information in the hopes of resolving this matter without further intervention from the Court. 1 of 2 FILED: KINGS COUNTY CLERK 07/01/2020 06:59 PM INDEX NO. 503139/2020 NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 07/01/2020 6. Plaintiffs have indicated that they are not opposed to the Defendants receiving an additional fourteen (14) days to file its responsive pleading. However, Defendants believe that an additional thirty (30) days is appropriate to allow the parties to continue their exchange of information and allow Defendants time to prepare a responsive pleading if necessary. 7. This request is made in good faith and is not being made for purposes of delay. This is the Defendants’ first request for an extension of time to respond to the Complaint. 8. Accordingly, Defendants request an additional thirty (30) days, up to and including July 30, 2020, to file their responsive pleading. Wherefore, Defendants move for entry of an order providing them to and through July 30, 2020 to file their responsive pleading, and any other relief this Court deems just and proper. Dated: New York, New York July 1, 2020 Respectfully Submitted, Vivek Jayaram, Esq. Jayaram Law, Inc. 142 West 57th Street 11th Floor New York, NY 10019 vivek@jayaramlaw.com T: 646.325.9855 2 of 2