On February 03, 2020 a
Letter,Correspondence
was filed
involving a dispute between
Deborah Weber Individually And On Behalf Of Others Similarly Situated,
Deborah Weber
Individually And On Behalf Of Others Similarly Situated,
and
Buffalo Beacon Corporation,
Nathanial C. Webster M.D.,
Quest Diagnostics Of Pennsylvania Inc.,
for Torts - Other Negligence (Negligence & Prof Malprac)
in the District Court of Erie County.
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FILED: ERIE COUNTY CLERK 05/03/2024 01:14 PM INDEX NO. 801624/2020
NYSCEF DOC. NO. 79 RECEIVED NYSCEF: 05/03/2024
May 3, 2024
ATTORNEYS
BY NYSCEF Filing Stephen G. Schwarz
John A. Falk
Hadley E. Lundback**
Hon. John DelMonte Jennifer L. Fay
Supreme Court Justice Kristin A. Merrick
Part 36 - 10th floor
50 Delaware Avenue Matthew F. Belanger*
Joseph A. Regan
Buffalo, NY 14202
Kathryn Lee Bruns
Joshua M. Mankoff***
Re: Weber v. Quest and Beacon, Lesley E. Niebel*
Index #: 801624/2020 Teagan C. Dolan
OF COUNSEL
Dear Justice DelMonte:
Brian M. Zorn
On behalf of Plaintiff in the above action, this letter is being filed pursuant to the RETIRED
discussion that occurred during yesterday’s conference with the Court. Angelo G. Faraci
Paul K. Lange
Plaintiff is hereby withdrawing her Motion to Compel Defendant Beacon to provide
(1935‐2022)
appropriate answers to Interrogatories and responses to Plaintiff’s Notice to Admit.
(NYSCEF Doc. No. 64). According to the Docket, Defendant never filed a Cross- NURSE CONSULTANTS
Motion for a Protective Order but requested that relief only in an Attorney’s Ann M. Steinmetz, RN
Affirmation in response to Plaintiff’s Motion to Compel. (NYSCEF Doc. No. 75). Melissa A. Yeager, RN
The deposition notice for a corporate witness that was discussed during the BUFFALO OFFICE
conference was filed as Exhibit A to Plaintiff’s Reply Affirmation (NYSCEF Doc. Faraci Lange, LLP
No. 78). This deposition notice is dated three days after Defendant Beacon filed its 6225 Sheridan Drive
Attorney’s Affirmation in Opposition to Plaintiff’s Motion to Compel that had Suite 306
Buffalo, NY 14221
requested the Protective Order. Thus, it is Plaintiff’s position that the withdrawal of
Plaintiff’s motion leaves nothing pending for the Court to resolve.
Thank you. *Also admitted in MA
**Also admitted in NJ
***Also admitted in NJ, PA,
Sincerely,
IA & DC
Stephen G. Schwarz
sschwarz@faraci.com
1882 South Winton Road, Suite 1, Rochester, New York 14618
PHONE 585.325.5150 • TOLL-FREE 888.325.5150 • FAX 585.325.3285 • faraci.com
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Document Filed Date
May 03, 2024
Case Filing Date
February 03, 2020
Category
Torts - Other Negligence (Negligence & Prof Malprac)
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FILED: ERIE COUNTY CLERK 05/03/2024 01:14 PM INDEX NO. 801624/2020 NYSCEF DOC. NO. 79 RECEIVED NYSCEF: 05/03/2024 May 3, 2024 ATTORNEYS BY NYSCEF Filing Stephen G. Schwarz John A. Falk Hadley E. Lundback** Hon. John DelMonte Jennifer L. Fay Supreme Court Justice Kristin A. Merrick Part 36 - 10th floor 50 Delaware Avenue Matthew F. Belanger* Joseph A. Regan Buffalo, NY 14202 Kathryn Lee Bruns Joshua M. Mankoff*** Re: Weber v. Quest and Beacon, Lesley E. Niebel* Index #: 801624/2020 Teagan C. Dolan OF COUNSEL Dear Justice DelMonte: Brian M. Zorn On behalf of Plaintiff in the above action, this letter is being filed pursuant to the RETIRED discussion that occurred during yesterday’s conference with the Court. Angelo G. Faraci Paul K. Lange Plaintiff is hereby withdrawing her Motion to Compel Defendant Beacon to provide (1935‐2022) appropriate answers to Interrogatories and responses to Plaintiff’s Notice to Admit. (NYSCEF Doc. No. 64). According to the Docket, Defendant never filed a Cross- NURSE CONSULTANTS Motion for a Protective Order but requested that relief only in an Attorney’s Ann M. Steinmetz, RN Affirmation in response to Plaintiff’s Motion to Compel. (NYSCEF Doc. No. 75). Melissa A. Yeager, RN The deposition notice for a corporate witness that was discussed during the BUFFALO OFFICE conference was filed as Exhibit A to Plaintiff’s Reply Affirmation (NYSCEF Doc. Faraci Lange, LLP No. 78). This deposition notice is dated three days after Defendant Beacon filed its 6225 Sheridan Drive Attorney’s Affirmation in Opposition to Plaintiff’s Motion to Compel that had Suite 306 Buffalo, NY 14221 requested the Protective Order. Thus, it is Plaintiff’s position that the withdrawal of Plaintiff’s motion leaves nothing pending for the Court to resolve. Thank you. *Also admitted in MA **Also admitted in NJ ***Also admitted in NJ, PA, Sincerely, IA & DC Stephen G. Schwarz sschwarz@faraci.com 1882 South Winton Road, Suite 1, Rochester, New York 14618 PHONE 585.325.5150 • TOLL-FREE 888.325.5150 • FAX 585.325.3285 • faraci.com 1 of 1