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FILED: KINGS COUNTY CLERK 05/17/2017 12:24 PM INDEX NO.

514736/2015
NYSCEF DOC. NO. 116 RECEIVED NYSCEF: 05/17/2017

SUPREME COURT OF THE STATE OF NEW YORK


COUNTY OF KINGS

A.J. RICHARD & SONS, INC.


Index No. 514736/2015
Plaintiff,

-against- Part Comm. 11

FOREST CITY RATNER COMPANIES, LLC,

Defendant.

STIPULATION EXTENDING DISCLOSURE DEADLINES

WHEREAS, under the disclosure deadlines set forth in the Preliminary Conference

Order, dated August 23, 2016 (Dkt. No. 76), Plaintiff A.J. Richard & Son, Inc.'s ("A.J. Richard")

expert disclosures deadline would have been March 15, 2017, Defendant Forest City Ratner

Companies, LLC's ("Forest City") expert disclosure deadline would have been April 15, 2017,

and the end date for all disclosure would have been May 15, 2017;

WHEREAS, on February 17, 2017, A.J. Richard served a Subpoena for

Deposition/Documents (the "Subpoena") on non-party Greenland Atlantic Yards, LLC

("Greenland");

WHEREAS, in March 2017, counsel for A.J. Richard and counsel for Forest City

conferred and agreed, in light of ongoing party and third-party discovery, including the

Greenland Subpoena, to extend A.J. Richard's expert disclosure deadline until 30 days after

Greenland's compliance with the Subpoena, to be followed in 30 days by Forest City's expert

disclosure deadline and 30 days thereafter by the end of all disclosure; and

WHEREAS, counsel for Greenland has informed counsel for A.J. Richard that Greenland

expects its production in response to the Subpoena to be complete by the week of May 29, 2017;

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FILED: KINGS COUNTY CLERK 05/17/2017 12:24 PM INDEX NO. 514736/2015
NYSCEF DOC. NO. 116 RECEIVED NYSCEF: 05/17/2017

IT IS HEREBY STIPULATED AND AGREED by and between the undersigned counsel

for A.J. Richard and Forest City, that the remaining disclosure deadlines are modified as follows:

A.J. Richard shall provide expert disclosure by: July 31, 2017;

Forest City shall provide expert disclosure by: August 31, 2017; and

End date for all disclosure: September 29, 2017;

Provided, however, that in the event the Greenland production is not complete by June 30, 2017,

the Parties shall renegotiate these disclosure deadlines as reasonably necessary to provide the

Parties sufficient time for expert disclosure.

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FILED: KINGS COUNTY CLERK 05/17/2017 12:24 PM INDEX NO. 514736/2015
NYSCEF DOC. NO. 116 RECEIVED NYSCEF: 05/17/2017

IT IS HEREBY FURTHER STIPULATED AND AGREED that this stipulation may be

signed in counterparts, and facsimile and e-mail signatures will constitute originals for purposes

of this stipulation.

Dated: May _, 2017 Dated: May H, 2017

CRAVATH, SWAINE & MOORE LLP KRAMER LEVIN NAFTALIS &


FRANKEL LLP

By: By:
Robert H. Baron Harold P. W6injB erger
0,
Rory A. Leraris Susan Jacquemot
Members of the Firm Leah S. Friedman

Worldwide Plaza 1177 Avenue of the Americas


825 Eighth Avenue New York, NY 10036
New York, NY 10019 (212)715-9100
(212) 474-1000
LONGO & D'APICE
GOLDBERG & RIMBERG PLLC Mark A. Longo, Esq.
Israel Goldberg 26 Court Street, Suite 1700
Steven A. Weg Brooklyn, NY 11242
115 Broadway, 3rd Floor (718) 722-7300
New York, NY 10006
(212) 697-3250 Attorneys for Defendant Forest City Ratner
Companies, LLC
DOMENIC M. RECCHIA, JR.
172 Gravesend Neck Road
Brooklyn, NY 11223
(718) 336-5550

Attorneys for Plaintiff A.J. Richard & Sons,


Inc.

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