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S.D.N.Y.Procedural orderFiled May 6, 2021

Nachshen v. BPP ST Owner LLC

Judge
Vyskocil
Docket
1:18-cv-10994-JPC
Court
U.S. District Court · Southern District of New York
Pages
2
Civil Procedure
In one sentence

In Nachshen v. BPP ST Owner LLC, Judge Vyskocil granted an extension to seek substitution for deceased plaintiff Steven Nachshen.

Who this affects

Steven Nachshen’s estate and the parties to the action, because the court extended the time to seek substitution and required a status update about the estate representative’s appointment.

What happened

In Steven Nachshen v. BPP ST Owner LLC and Citibank, N.A., Nachshen’s lawyers told the court that he had died and that Louise Nachshen would become administrator of his estate. She intended to continue the case on his behalf, but her appointment was still pending.

The lawyers asked for more time to file a motion replacing Nachshen with the estate’s representative. They cited delays in New York County Surrogate’s Court and also argued that the 90-day deadline had not yet begun because an earlier notice of death was allegedly invalid and did not identify an estate representative.

Judge Mary Kay Vyskocil granted the request for an extension. The court ordered a status letter by June 7, 2021, about the appointment process.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Nachshen v. BPP ST Owner LLC · No. 1:18-cv-10994-JPC
Judge
Vyskocil
Date
May 6, 2021

Background

Steven Nachshen’s lawyers stated that Nachshen had died. They reported that Louise Nachshen would become the administrator of his estate and had filed a petition for letters of administration in New York State Surrogate’s Court in New York County. The lawyers said Louise Nachshen intended to continue the action on Nachshen’s behalf.

Request

The lawyers asked the court to extend the time to file a motion for substitution while the Surrogate’s Court considered Louise Nachshen’s appointment. A substitution motion would seek to replace the deceased plaintiff with the estate’s representative. The lawyers cited delays they attributed to increased filings during the COVID-19 pandemic. They also argued that the 90-day period for filing a substitution motion had not begun because an earlier notice of death was not valid and did not identify an estate representative.

Ruling

Judge Mary Kay Vyskocil granted the request for an extension of time to move for substitution. The court ordered that a status letter be filed by June 7, 2021. The text provided does not state the court’s ruling on the underlying claims in the action.

Effect

The order extended the time for addressing substitution of a representative for Nachshen’s estate. It did not decide the merits of the underlying dispute.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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