Murtha Cullina has been retained by defendants Conquest Secured Lending Fund, LLCand Fidelis Investors, LLC (the “Defendants”) as their counsel in the above-referenced action.

Case No. 2384CV0287 1 The conference is in regard to your client's inadequate discovery responses to see if we can narrow the issues or avoid filing a motion to compel further answers and document production.

Case No. 2384CV0287 4 You and | bath know | do not need to lay out every specific detail we intend to raise in a motion to compel in writing before we can conduct a Rule 9C conference.

RE: Rierner &Braunstein LLP vvAConquest Secured Lending Fund, LLC et al, Case No.: 2384CV02871 Date Filed 11/5/2024 3:18 PM Superior Court - Suffolk Docket Number 2384CV02871 We can discuss all ofthis at 3pm.

Hf you do net intend to respond to the interrogatories and Docurnent Requests by the respective deadlines, | will file a motion to compel Rierner’s responses.

DEFENDANT NOS. 1-25, the Names of “John Doe” Defendants Being Fictitious and Unknown to Plaintiff, the Persons and Entities Intended Being Those Who May be In Possession of, or May Have Possessory Liens or Other Interests in the Premises Herein Described, Defendants.

Please take notice that on April 27, 2023, with respect to the above captioned action, this Honorable Court Ordered motions #003, #004 and #005 including any cross-motions therein, be denied without prejudice and respectfully referred said action to His Honor, Justice Leonard Livote with leave to make the aforesaid motion before Justice Livote.

Such was entered in the Office of the Queens County Clerk for the Supreme Court, State of New York, County of Queens.

Dated: May 9th, 2023 Queens, New York Yours, etc.,

Wood, Esq. 30-50 Whitestone Expy 402 Flushing, NY 11354 Counsel for Defendants Operr Plaza, LLC, Clean Air Car Service & Parking Branch Two, LLC, Kevin S. Wang, Clean Air Car Service & Parking Corporation, Clean Air Car Service & Parking Branch 3, LLC, Operr Technologies Inc., Operr Service Bureau Inc., Operr Group, Inc., and Board of Managers of The Prince Plaza Condominium

DEFENDANT NOS. 1-25, the Names of “John Doe” Defendants Being Fictitious and Unknown to Plaintiff, the Persons and Entities Intended Being Those Who May be In Possession of, or May Have Possessory Liens or Other Interests in the Premises Herein Described, Defendants.

Please take notice that on April 27, 2023, with respect to the above captioned action, this Honorable Court Ordered motions #003, #004 and #005 including any cross-motions therein, be denied without prejudice and respectfully referred said action to His Honor, Justice Leonard Livote with leave to make the aforesaid motion before Justice Livote.

Such was entered in the Office of the Queens County Clerk for the Supreme Court, State of New York, County of Queens.

Dated: May 9th, 2023 Queens, New York Yours, etc.,

Wood, Esq. 30-50 Whitestone Expy 402 Flushing, NY 11354 Counsel for Defendants Operr Plaza, LLC, Clean Air Car Service & Parking Branch Two, LLC, Kevin S. Wang, Clean Air Car Service & Parking Corporation, Clean Air Car Service & Parking Branch 3, LLC, Operr Technologies Inc., Operr Service Bureau Inc., Operr Group, Inc., and Board of Managers of The Prince Plaza Condominium

DEFENDANT NOS. 1-25, the Names of “John Doe” Defendants Being Fictitious and Unknown to Plaintiff, the Persons and Entities Intended Being Those Who May be In Possession of, or May Have Possessory Liens or Other Interests in the Premises Herein Described, Defendants.

Please take notice that on April 27, 2023, with respect to the above captioned action, this Honorable Court Ordered motions #003, #004 and #005 including any cross-motions therein, be denied without prejudice and respectfully referred said action to His Honor, Justice Leonard Livote with leave to make the aforesaid motion before Justice Livote.

Such was entered in the Office of the Queens County Clerk for the Supreme Court, State of New York, County of Queens.

Dated: May 9th, 2023 Queens, New York Yours, etc.,

Wood, Esq. 30-50 Whitestone Expy 402 Flushing, NY 11354 Counsel for Defendants Operr Plaza, LLC, Clean Air Car Service & Parking Branch Two, LLC, Kevin S. Wang, Clean Air Car Service & Parking Corporation, Clean Air Car Service & Parking Branch 3, LLC, Operr Technologies Inc., Operr Service Bureau Inc., Operr Group, Inc., and Board of Managers of The Prince Plaza Condominium

Page 1 of 3 Plaintiff IV-CVCF NEB I Trust as Assignee of CVCF Fund Funding I-NEB, LLC (“Plaintiff”) commenced this action against, among others, Defendants Kevin S. Wang, Clean Air Car Service & Parking Corporation, Clean Air Car Service & Parking Branch 3, LLC, Operr Technologies Inc., Operr Service Bureau Inc., and Operr Group, Inc. (collectively “Defendants”) to foreclose a mortgage on real property located at 37-31 10th Street, Long Island City, NY, 11101, Block 360, Lot 7 and 37-20 Prince Street, Unit PU, Flushing, NY, 11354 Block 4972, Lot 1104 (“Premises”).

Index No. 714973/2021 was commenced on June 30, 2021, and seeks to set aside the UCC sale of Operr Plaza LLC and Clean Air Car Service & Parking Branch Two, LLC as the Complaint states that the sale was not conducted in a commercially reasonable manner.3 Index No. 723126/2021 was commenced on October 14, 2021, and seeks, among other things, access to the Premises to make repairs.

Index No. 720521/2021 was commenced September 13, 2021, and seeks damages for, among other things, tortious interference with business as to the parking garage at the Premises.

Given the circumstances, and in order to avoid inconsistent holdings, the motions are denied without prejudice with leave to seek relief before Justice Leonard Livote.

In accordance with the foregoing, it is ORDERED that motion sequence 3, 4, and 5 and any cross-motions therein4 are denied without prejudice to the parties moving for such relief before Justice Leonard Livote; and it is further

Page 1 of 3 Plaintiff IV-CVCF NEB I Trust as Assignee of CVCF Fund Funding I-NEB, LLC (“Plaintiff”) commenced this action against, among others, Defendants Kevin S. Wang, Clean Air Car Service & Parking Corporation, Clean Air Car Service & Parking Branch 3, LLC, Operr Technologies Inc., Operr Service Bureau Inc., and Operr Group, Inc. (collectively “Defendants”) to foreclose a mortgage on real property located at 37-31 10th Street, Long Island City, NY, 11101, Block 360, Lot 7 and 37-20 Prince Street, Unit PU, Flushing, NY, 11354 Block 4972, Lot 1104 (“Premises”).

Index No. 714973/2021 was commenced on June 30, 2021, and seeks to set aside the UCC sale of Operr Plaza LLC and Clean Air Car Service & Parking Branch Two, LLC as the Complaint states that the sale was not conducted in a commercially reasonable manner.3 Index No. 723126/2021 was commenced on October 14, 2021, and seeks, among other things, access to the Premises to make repairs.

Index No. 720521/2021 was commenced September 13, 2021, and seeks damages for, among other things, tortious interference with business as to the parking garage at the Premises.

Given the circumstances, and in order to avoid inconsistent holdings, the motions are denied without prejudice with leave to seek relief before Justice Leonard Livote.

In accordance with the foregoing, it is ORDERED that motion sequence 3, 4, and 5 and any cross-motions therein4 are denied without prejudice to the parties moving for such relief before Justice Leonard Livote; and it is further

Page 1 of 3 Plaintiff IV-CVCF NEB I Trust as Assignee of CVCF Fund Funding I-NEB, LLC (“Plaintiff”) commenced this action against, among others, Defendants Kevin S. Wang, Clean Air Car Service & Parking Corporation, Clean Air Car Service & Parking Branch 3, LLC, Operr Technologies Inc., Operr Service Bureau Inc., and Operr Group, Inc. (collectively “Defendants”) to foreclose a mortgage on real property located at 37-31 10th Street, Long Island City, NY, 11101, Block 360, Lot 7 and 37-20 Prince Street, Unit PU, Flushing, NY, 11354 Block 4972, Lot 1104 (“Premises”).

Index No. 714973/2021 was commenced on June 30, 2021, and seeks to set aside the UCC sale of Operr Plaza LLC and Clean Air Car Service & Parking Branch Two, LLC as the Complaint states that the sale was not conducted in a commercially reasonable manner.3 Index No. 723126/2021 was commenced on October 14, 2021, and seeks, among other things, access to the Premises to make repairs.

Index No. 720521/2021 was commenced September 13, 2021, and seeks damages for, among other things, tortious interference with business as to the parking garage at the Premises.

Given the circumstances, and in order to avoid inconsistent holdings, the motions are denied without prejudice with leave to seek relief before Justice Leonard Livote.

In accordance with the foregoing, it is ORDERED that motion sequence 3, 4, and 5 and any cross-motions therein4 are denied without prejudice to the parties moving for such relief before Justice Leonard Livote; and it is further