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. 41 RECEIVED NYSCEF: 02/24/2022
EXHIBIT “Q”
FILED: ONONDAGA COUNTY CLERK 02/24/2022 06:07 PM INDEX NO. 003917/2021
NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 02/24/2022
211 W Jefferson St.,Syracuse,NY 13202
Tel:315422.1152| Fax: 315422.1139
COONEY & PLLC -ccf law.com
FEARON,
ExperienceInnovation
Daniel R. Rose, Partner
drose@ccf-law.com
February 18, 2022
VIA E-MAIL AND REGULAR MAIL
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 Mr. Ryan:
This letter shall serve as the seventh and final attempt by Costello, Cooney & Fearon,
PLLC ("CC&F") to obtain discovery responses from Defendant. As you are well aware, we have
sent numerous letters and e-mails attempting to obtain this discovery and resolve any dispute. We
also recently had a telephone conversation on February 3, 2022, in which you committed to finally
providing Defendant's document production and responses to other outstanding discovery devices
the following week. It has now been over two (2) weeks since that representation, and we still
have heard nothing from Defendant.
Defendant's responses are now several d•r delayed-we served our Notice to Produce
on October 11, 2021, now five (5) months ago. Defendant has not timely objected, nor provided
any reasonable excuse for the extreme delay. If we have not received Defendant's complete and
proper responses in our office by Wednesday, February 23, 2022, we will have no choice but to
seek immediate judicial relief.
We thank you for your anticipated immediate attention to these matters.
Very truly yours,
COSTELLO, COONEY & FE O , PLLC
Daniel R. Rose
DRR/lja
ALBANY OFFICE CAZENOVIA OFFICE
220 Columbia Turnpike| Rs;:sselau,
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. 41 RECEIVED NYSCEF: 02/24/2022 EXHIBIT “Q” FILED: ONONDAGA COUNTY CLERK 02/24/2022 06:07 PM INDEX NO. 003917/2021 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 02/24/2022 211 W Jefferson St.,Syracuse,NY 13202 Tel:315422.1152| Fax: 315422.1139 COONEY & PLLC -ccf law.com FEARON, ExperienceInnovation Daniel R. Rose, Partner drose@ccf-law.com February 18, 2022 VIA E-MAIL AND REGULAR MAIL 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 Mr. Ryan: This letter shall serve as the seventh and final attempt by Costello, Cooney & Fearon, PLLC ("CC&F") to obtain discovery responses from Defendant. As you are well aware, we have sent numerous letters and e-mails attempting to obtain this discovery and resolve any dispute. We also recently had a telephone conversation on February 3, 2022, in which you committed to finally providing Defendant's document production and responses to other outstanding discovery devices the following week. It has now been over two (2) weeks since that representation, and we still have heard nothing from Defendant. Defendant's responses are now several d•r delayed-we served our Notice to Produce on October 11, 2021, now five (5) months ago. Defendant has not timely objected, nor provided any reasonable excuse for the extreme delay. If we have not received Defendant's complete and proper responses in our office by Wednesday, February 23, 2022, we will have no choice but to seek immediate judicial relief. We thank you for your anticipated immediate attention to these matters. Very truly yours, COSTELLO, COONEY & FE O , PLLC Daniel R. Rose DRR/lja ALBANY OFFICE CAZENOVIA OFFICE 220 Columbia Turnpike| Rs;:sselau, NY12144 5MillStreet| Cazenovia, NY13035