On April 23, 2021 a
Party Notice
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 05/11/2022 04:40 PM INDEX NO. 003917/2021
NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 05/11/2022
STATE OF NEW YORK
SUPREME COURT COUNTY OF ONONDAGA
COSTELLO, COONEY & FEARON, PLLC,
Plaintiff,
NOTICE OF CROSS MOTION
vs.
Index No.: 003917/2021
MELINDA BURDICK BOWE,
Defendant.
Motion Made By: Defendant, Melinda Burdick Bowe
Directed To: Plaintiff, Costello, Cooney & Fearon, PLLC
Date, Time and Place of Hearing: May 25, 2022, 10:00 a.m.
Supporting Papers: Affidavit of Andrew J. Ryan, Esq., sworn to the 11th day of
May, 2022 together with exhibits annexed thereto;
Affirmation of Melinda B. Bowe, Esq., dated May 11, 2022,
together with exhibit annexed thereto;
Memorandum of Law
Relief Requested: An Order:
Compelling the Plaintiff to provide disclosure pursuant
to CPLR 3126 and in the event that the Plaintiff does not
comply, an Order pursuant to CPLR 3124 precluding
the Plaintiff from submitting evidence at trial responsive
to those discovery demands
Grounds for Relief: CPLR § 3126 and CPLR 3124
Answering Papers: Answering documents, if any, must be served at least seven
(7) days prior to the return date of this motion, pursuant to
CPLR § 2214(b).
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FILED: ONONDAGA COUNTY CLERK 05/11/2022 04:40 PM INDEX NO. 003917/2021
NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 05/11/2022
DATED: May 11, 2022 WOODS OVIATT GILMAN LLP
Rochester, New York
By:/s/ Andrew J. Ryan
Andrew J. Ryan, Esq.
Rachel R. Pawlak, Esq.
Attorneys for Defendant
1900 Bausch & Lomb Place
Rochester, New York 14604
585.987.2800
TO: Daniel R. Rose, Esq.
Attorneys for Plaintiff
Costello, Cooney & Fearon, PLLC
211 West Jefferson Street
Syracuse, NY 13202
315.422.1152
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Document Filed Date
May 11, 2022
Case Filing Date
April 23, 2021
Category
Torts - Other (Unjust Enrichment/Convers)
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FILED: ONONDAGA COUNTY CLERK 05/11/2022 04:40 PM INDEX NO. 003917/2021 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 05/11/2022 STATE OF NEW YORK SUPREME COURT COUNTY OF ONONDAGA COSTELLO, COONEY & FEARON, PLLC, Plaintiff, NOTICE OF CROSS MOTION vs. Index No.: 003917/2021 MELINDA BURDICK BOWE, Defendant. Motion Made By: Defendant, Melinda Burdick Bowe Directed To: Plaintiff, Costello, Cooney & Fearon, PLLC Date, Time and Place of Hearing: May 25, 2022, 10:00 a.m. Supporting Papers: Affidavit of Andrew J. Ryan, Esq., sworn to the 11th day of May, 2022 together with exhibits annexed thereto; Affirmation of Melinda B. Bowe, Esq., dated May 11, 2022, together with exhibit annexed thereto; Memorandum of Law Relief Requested: An Order: Compelling the Plaintiff to provide disclosure pursuant to CPLR 3126 and in the event that the Plaintiff does not comply, an Order pursuant to CPLR 3124 precluding the Plaintiff from submitting evidence at trial responsive to those discovery demands Grounds for Relief: CPLR § 3126 and CPLR 3124 Answering Papers: Answering documents, if any, must be served at least seven (7) days prior to the return date of this motion, pursuant to CPLR § 2214(b). {8851565: } 1 of 2 FILED: ONONDAGA COUNTY CLERK 05/11/2022 04:40 PM INDEX NO. 003917/2021 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 05/11/2022 DATED: May 11, 2022 WOODS OVIATT GILMAN LLP Rochester, New York By:/s/ Andrew J. Ryan Andrew J. Ryan, Esq. Rachel R. Pawlak, Esq. Attorneys for Defendant 1900 Bausch & Lomb Place Rochester, New York 14604 585.987.2800 TO: Daniel R. Rose, Esq. Attorneys for Plaintiff Costello, Cooney & Fearon, PLLC 211 West Jefferson Street Syracuse, NY 13202 315.422.1152 {8851565: } 2 2 of 2