On April 21, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Richard Von Der Lieth,
and
Barbara Giordano
A K A Barbara Leonaggeo A K A Barbara Giordano-Leonaggeo,
Catania, Mahon, Milligram & Rider, Pllc,
H&L Equine, Llc,
Jack Giordano,
Jane Doe
1-10,
John Doe
1-10,
John Doe 1-10 And Jane Doe 1-10, As Possible Heirs And Distributees Of The Interest Of Jack Giordano, If Deceased,
M-M2 Re Holdings 4, Llc,
Portfolio Recovery Associates, Llc,
Razor Capital Ii, Llc
A P O Credit One Bank, N.A.,
Roger Leonaggeo,
for Real Property - Mortgage Foreclosure - Commercial
in the District Court of Dutchess County.
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GUNILLA P. FARINGER
(GUNILLA PEREZ-FARINGER)
34 SOUTH BROADWAY, SUITE 710
ATTORNEY AT LAW WHITE PLAINS, NEW YORK 10601
(914) 574-3708 PH
(9 14) 948- I 800 F
FARINGERLAW@GMAIL.COM
WWW.FARINGER-LAW.COM
January 26, 2022
Hon. Maria G. Rosa
Supreme Court of the State of New York
County of Dutchess
10 Market Street
Poughkeepsie, NY 12601
Re.: von der Lieth v. Giordano et al., Index No. 2021-51452
LETTER MOTION FOR EXTENTION OF TIME
Dear Judge Rosa,
As the Court will recall, the undersigned represents the Defendants in the above referenced
case, Barbara Giodano-Leonaggeo and Robert Leonaggeo.
As the Court knows, on today's date Plaintiff filed his documents in reply to his motion for
summary judgment and in opposition to our cross-motion. Therefore, under the rules of procedure
it is my understanding that our reply to Plaintiffs opposition to our cross-motion is due on February
7.
Unfortunately I will not be able to draft and submit our reply by that date. The reason for
this situation is that I am currently coping with serious illness in my immediate family, and in
addition I will be leaving the country on Friday for an important family matter that cannot be
postponed. I am a solo practitioner and have no colleague to take over in my stead when faced with
deadlines that are impossible to meet.
Therefore it is my great hope that the Court will grant us a three-weeks extension of time to
submit our reply for three weeks, until February 28, or for such time that the Court finds just and
GUNILLA P. FAR!NGER, ESQ.
proper. I will return on February 7 and it is my great hope that the Court will agree to at least a
week after that to allow enough time to prepare our motion papers. Under my very difficult current
circumstances I do not have the resources to draft the documents before I leave.
Thankyou in advance to your attention to this matter.
Cc:
Anthony Carlini
2
Document Filed Date
January 26, 2022
Case Filing Date
April 21, 2021
Category
Real Property - Mortgage Foreclosure - Commercial
Status
Disposed-Court Date/Application Pending
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GUNILLA P. FARINGER (GUNILLA PEREZ-FARINGER) 34 SOUTH BROADWAY, SUITE 710 ATTORNEY AT LAW WHITE PLAINS, NEW YORK 10601 (914) 574-3708 PH (9 14) 948- I 800 F FARINGERLAW@GMAIL.COM WWW.FARINGER-LAW.COM January 26, 2022 Hon. Maria G. Rosa Supreme Court of the State of New York County of Dutchess 10 Market Street Poughkeepsie, NY 12601 Re.: von der Lieth v. Giordano et al., Index No. 2021-51452 LETTER MOTION FOR EXTENTION OF TIME Dear Judge Rosa, As the Court will recall, the undersigned represents the Defendants in the above referenced case, Barbara Giodano-Leonaggeo and Robert Leonaggeo. As the Court knows, on today's date Plaintiff filed his documents in reply to his motion for summary judgment and in opposition to our cross-motion. Therefore, under the rules of procedure it is my understanding that our reply to Plaintiffs opposition to our cross-motion is due on February 7. Unfortunately I will not be able to draft and submit our reply by that date. The reason for this situation is that I am currently coping with serious illness in my immediate family, and in addition I will be leaving the country on Friday for an important family matter that cannot be postponed. I am a solo practitioner and have no colleague to take over in my stead when faced with deadlines that are impossible to meet. Therefore it is my great hope that the Court will grant us a three-weeks extension of time to submit our reply for three weeks, until February 28, or for such time that the Court finds just and GUNILLA P. FAR!NGER, ESQ. proper. I will return on February 7 and it is my great hope that the Court will agree to at least a week after that to allow enough time to prepare our motion papers. Under my very difficult current circumstances I do not have the resources to draft the documents before I leave. Thankyou in advance to your attention to this matter. Cc: Anthony Carlini 2