On April 23, 2021 a
Letter,Correspondence
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
211W. Je fferson
St.,Syracuse, NY 13202
Tel:315.422.1152 i Fax: 315.422.1139
"="fla n)
COONEY & FEARON, PLLC
ExperienceInnovation Daniel R. Rose, Partner
drose@ccf-law.com
April 6, 2022
VIA NYSCEF
Hon. Deborah H. Karalunas, J.S.C.
Onondaga County Courthouse
401 Montgomery Street
Syracuse, New York 13202
Re: Costello, Cooney & Fearon, PLLC v. Bowe
Index No: 003917/2021
Dear Justice Karalunas:
As the Court is aware, I represent the plaintiff in the above-referenced matter. Last Thursday,
defendant served certain discovery responses in this matter. While we are in the process of reviewing
those responses, Mr. Ryan and 1 did have a lengthy telephone conversation this morning about possibly
limiting the issues before the Court in the pending motion to compel. As we continue to work through
these matters, we would jointly request the pending motion be adjourned to May 25, 2022, to allow for
us to provide some additional responses to defendant, and to complete our review of defendant's
responses to narrow the scope of our requests to the Court.
Ifthis request meets with the Court's approval, we would respectfully request that the Court
order"
"so this letter.
By true copy hereof, I am advising opposing counsel of this communication.
We thank the Court in advance for itscourtesies in this regard. Should you have any questions
or comments, please do not hesitate to contact me.
Respectfully submitted,
COSTELLO ONEY & FEA O ,PLLC
Daniel R. Rose
DRR/lja
cc: Andrew J. Ryan, Esq. (via NYSCEF)
SO ORDERED:
Hon. Deborah H. Karalunas, J.S.C.
ALBANY OFFICE CAZENOVIA OFFICE
220 ColumbiaTurnpike \ Rensselaer,NY12144 5MillStreet| Cazenovia, NY 13035
Document Filed Date
April 06, 2022
Case Filing Date
April 23, 2021
Category
Torts - Other (Unjust Enrichment/Convers)
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211W. Je fferson St.,Syracuse, NY 13202 Tel:315.422.1152 i Fax: 315.422.1139 "="fla n) COONEY & FEARON, PLLC ExperienceInnovation Daniel R. Rose, Partner drose@ccf-law.com April 6, 2022 VIA NYSCEF Hon. Deborah H. Karalunas, J.S.C. Onondaga County Courthouse 401 Montgomery Street Syracuse, New York 13202 Re: Costello, Cooney & Fearon, PLLC v. Bowe Index No: 003917/2021 Dear Justice Karalunas: As the Court is aware, I represent the plaintiff in the above-referenced matter. Last Thursday, defendant served certain discovery responses in this matter. While we are in the process of reviewing those responses, Mr. Ryan and 1 did have a lengthy telephone conversation this morning about possibly limiting the issues before the Court in the pending motion to compel. As we continue to work through these matters, we would jointly request the pending motion be adjourned to May 25, 2022, to allow for us to provide some additional responses to defendant, and to complete our review of defendant's responses to narrow the scope of our requests to the Court. Ifthis request meets with the Court's approval, we would respectfully request that the Court order" "so this letter. By true copy hereof, I am advising opposing counsel of this communication. We thank the Court in advance for itscourtesies in this regard. Should you have any questions or comments, please do not hesitate to contact me. Respectfully submitted, COSTELLO ONEY & FEA O ,PLLC Daniel R. Rose DRR/lja cc: Andrew J. Ryan, Esq. (via NYSCEF) SO ORDERED: Hon. Deborah H. Karalunas, J.S.C. ALBANY OFFICE CAZENOVIA OFFICE 220 ColumbiaTurnpike \ Rensselaer,NY12144 5MillStreet| Cazenovia, NY 13035