On April 23, 2021 a
Exhibit,Appendix
was filed
involving a dispute between
Costello, Cooney & Fearon, Pllc,
and
Melinda Burdick Bowe,
for Torts - Other (Unjust Enrichment/Convers)
in the District Court of Onondaga County.
Preview
FILED: ONONDAGA COUNTY CLERK 02/24/2022 06:07 PM INDEX NO. 003917/2021
NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 02/24/2022
EXHIBIT “N”
FILED: ONONDAGA COUNTY CLERK 02/24/2022 06:07 PM INDEX NO. 003917/2021
NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 02/24/2022
211 W Jef ferson
St.,Syracuse, NY 13202
T E LLOS OC
Tel:315.422.1152 | Fax:
315.422.1139
www.ccf-law.com
COONEY & FEARON, PLLC
ExperienceInnovation Daniel R. Rose, Partner
drose@ccf-law.com
January 4, 2022
Andrew J. Ryan, Esq.
Woods Oviatt Gilman, LLP
1900 Bausch & Lomb Place
Rochester, New York 14604
Re: Costello, Cooney & Fearon, PLLC v. Bowe
Index No. 003917/2021
Dear Andy:
As a follow-up to our document productions of December 10, 2021 and December 16,
2021, and correspondence of those dates, enclosed please find CC&F's privilege log in connection
with those productions. To the extent our previously produced documents contain redactions not
reflected within the privilege log, those portions of the e-mail commimications were not responsive
to defendant's demands.
Additionally, as we noted in our previous correspondence, we stillhave not received any
responses to our Demand for Defendant's Residence, served September 15, 2021; First Notice to
Produce, served September 30, 2021; Demand for Tax Returns served October 14, 2021; or our
First Set of Interrogatories served November 16, 2021. Notwithstanding the Court's stay,
Defêñdañt's responses are delinquent. Please advise when we may reasonably expect responses
to our various CPLR demands, Notice to Produce and Interrogatories.
Finally, we once. again demand Defendant provide availability for her deposition. in
February 2022. We have now asked for her to provide her availability on four (4) previous
occasions, and have received no response to those requests. Please advise without further delay
when Defendant is available for deposition.
We thank you for your anticipated attention to these matters. Should you have any
questions or comments, please do not hesitate to contact me.
. . Very truly yours,
COSTELLO -.OONEY & FE RO , PLLC
Daniel R. Rose
DRR/la
Enc.
ALBANY OFFICE . CAZENOVIA OFFICE
220 Columbia Turnpike| Rensselaer, NY12144 . 5MillStreet| Cazenovia, NY13035
Document Filed Date
February 24, 2022
Case Filing Date
April 23, 2021
Category
Torts - Other (Unjust Enrichment/Convers)
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Preview
FILED: ONONDAGA COUNTY CLERK 02/24/2022 06:07 PM INDEX NO. 003917/2021 NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 02/24/2022 EXHIBIT “N” FILED: ONONDAGA COUNTY CLERK 02/24/2022 06:07 PM INDEX NO. 003917/2021 NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 02/24/2022 211 W Jef ferson St.,Syracuse, NY 13202 T E LLOS OC Tel:315.422.1152 | Fax: 315.422.1139 www.ccf-law.com COONEY & FEARON, PLLC ExperienceInnovation Daniel R. Rose, Partner drose@ccf-law.com January 4, 2022 Andrew J. Ryan, Esq. Woods Oviatt Gilman, LLP 1900 Bausch & Lomb Place Rochester, New York 14604 Re: Costello, Cooney & Fearon, PLLC v. Bowe Index No. 003917/2021 Dear Andy: As a follow-up to our document productions of December 10, 2021 and December 16, 2021, and correspondence of those dates, enclosed please find CC&F's privilege log in connection with those productions. To the extent our previously produced documents contain redactions not reflected within the privilege log, those portions of the e-mail commimications were not responsive to defendant's demands. Additionally, as we noted in our previous correspondence, we stillhave not received any responses to our Demand for Defendant's Residence, served September 15, 2021; First Notice to Produce, served September 30, 2021; Demand for Tax Returns served October 14, 2021; or our First Set of Interrogatories served November 16, 2021. Notwithstanding the Court's stay, Defêñdañt's responses are delinquent. Please advise when we may reasonably expect responses to our various CPLR demands, Notice to Produce and Interrogatories. Finally, we once. again demand Defendant provide availability for her deposition. in February 2022. We have now asked for her to provide her availability on four (4) previous occasions, and have received no response to those requests. Please advise without further delay when Defendant is available for deposition. We thank you for your anticipated attention to these matters. Should you have any questions or comments, please do not hesitate to contact me. . . Very truly yours, COSTELLO -.OONEY & FE RO , PLLC Daniel R. Rose DRR/la Enc. ALBANY OFFICE . CAZENOVIA OFFICE 220 Columbia Turnpike| Rensselaer, NY12144 . 5MillStreet| Cazenovia, NY13035