UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK 4 Ly t bag jf go Moy J Ex:

(List the full name(s) of the plaintiff{(s)/petitioner(s}.} -against- MOTION FOR EXTENSION OF TIME TO FILE NOTICE Lida yf Mp (Ope fee OF APPEAL

{List the full name(s} of the defendant(s}/respondent(s).} 5 □□

I move under Rule 4(a)(5) of the Federal Rules of Appellate Procedure for an extension of:time □ — □□ to file a notice of appeal in this action. I would like to appeal the judgment ay □□ entered in this actionon fi Ff » but did not file a notice of appeal within the require@2 7: □

time period because: / ~The motion is denied. An order remanding a case to the State court from which it was removed because the Court lacks subject matter jurisdiction, such as this Court's September 17, 2025 order (Doc. 5), is not reviewable on appeal or otherwise. See 28 U.S.C. 1447(d). Further, the Court notes that, to the {Explain here the excusable ne|extent defendant intends to make a "motion to void" in this . Court, this Court been divested of jurisdiction on the merits since remand. See, e.g., Jacobs v. ABN-AMRO Bank N.V., é _

(E.D.N.Y. Apr. 11, 2005). Dated: |SO ORDERED. Name (Last, First, Mi} / _, [Philip M. Halpern . □□ igh, Le United States District Judge ff □□ Fn 9 0% i4 Ode fl □ □□□ □ Address Dated: White Plains, New York c ge , October 20, 2025 Em Telephone Number” E-mail Address (if available)

Rev. 12/23/43

UNITED DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

Anthony Parks Plaintiff Case No. CV 25 7533 Vs.

Woodmont Ramaps LLC

MOTION FOR A 15-DAY EXTENSION OF TIME TO FILE APPEAL

1. The court issued a remand back to the Justice Court of Ramapo by order on September 172025 but appears to be filed on September 18, 2025, That means notice of appeal would be due on either October 17, 2025, or October 18", 2025. 2. First, | want to be clear that Plaintiff has no intention (at this point} of pursuing an appeal just on the remand itself. But Plaintiff does have concerns that pursuant to a violation 28 U.S.C 1446 {d}

(d)Notice to Adverse Parties and State Court.— Promptly after the filing of such notice of removal of a civil action the defendant or defendants shall give written notice thereof to all adverse parties and shall file a copy of the notice with the clerk of such State court, which shail effect the removal and the State court shall proceed no further unless and until the case is remanded.

3, This is governed by strict statute regardless of whether a case was deemed removabie or not.

4, There was a violation of this statute by the state court during the time

of removal which raises a void issue. Plaintiff will file a specific motion on that ithe next coming days when | receive the final order. 5. Therefore, plaintiff intends to file the appropriate motion to void and actions taken during the review period and service date.

6. Plaintiff does not want to file an appeal now which may take this matter

out of the jurisdiction of this court, unnecessarily and tie up judicial time

to request remand request with the second circuit.

7. Therefore, plaintiff is requesting a 15-day extension of time to file

an appeal while this matter is pending.

Anthony Parks __-

130 W. Pleasant Ave #327 Maywood, N.J. 07607 561-703-1283 October 17, 2025

PROOF OF SERVICE Plaintiff hereby certifies that a true copy of this motion was sent to Griffen Alexander 11 Broadway, Suite 615, New York, 10004 rinthony Parks