πŸ“‘ Motions & Responses



This page will list all significant court filings and correspondence made after the original complaints: motions to dismiss, answers, declarations, and more. Documents will be listed in chronological order with a short summary.

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πŸ•°οΈ Status Update – July 23, 2025

Counsel for Sills Cummis & Gross P.C. has requested an extension to respond to the complaint on behalf of multiple named defendants. The request was granted without prejudice, and a formal stipulation was signed and filed.

πŸ“¨ Request from Jason Teele, Sills Cummis & Gross

Mr. Teele submitted this request on July 21, 2025, and confirmed representation of the following parties named in the stipulation:

William (Billy) Procida, Derek Weissman, Dino Tomassetti, Ron Simoncini, Charles Florio, Andrew Kovar, Mario Procida, Peter Procida, 100 Mile Fund, LLC, 100 Mile REIT Inc., 100 Mile Renard Totowa LLC, Spruce Street Partners LLC, 468 Totowa Owner, LLC, and Sills Cummis & Gross P.C.

(collectively referred to as the β€œ100 Mile Defendants”)

Plaintiff David J. Garsia granted the extension through August 13, 2025.

This section will be updated with future motions, deadlines, and court responses as they are filed.

πŸ—“οΈ July 22, 2025 – Stipulations to Extend Response Deadlines

Plaintiff David J. Garsia has agreed to extend the deadline for defendants Eric R. Perkins and Patricia A. Staiano to respond to the adversary complaint. Each has until August 22, 2025 to answer, move, or otherwise respond.

πŸ—“οΈ July 22, 2025 – Stipulations to Extend Response Deadlines

Plaintiff David J. Garsia has agreed to extend the deadline for defendants Shari Hartstein and Harry Byrnes to respond to the adversary complaint. Each has until August 22, 2025 to answer, move, or otherwise respond.


πŸ•°οΈ Status Update – July 21, 2025

Counsel for four named defendants have each requested a 30-day extension to respond to the complaint. These requests have been granted, without prejudice to any party’s rights or defenses.

πŸ“¨ Request from Forman Holt

Attorney Michael Holt submitted a written request on behalf of defendants Harry Byrnes and Shari Hartstein, asking for a 30-day extension of time to file responsive pleadings.

Plaintiff David J. Garsia granted the request without prejudice.

πŸ“„ View PDF: Holt Extension & Response

πŸ“¨ Request from Riker Danzig LLP

Attorney John Harmon submitted a written request on behalf of defendants Eric Perkins and Patricia Staiano, also requesting a 30-day extension to file responsive pleadings.

Plaintiff David J. Garsia granted the request without prejudice.

πŸ“„ View PDF: Harmon Extension & Response

This section will be updated as additional extensions, motions, or filings are received.