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
1900 Bausch & Lomb Place WOODS 1900 Main Place Tower
Rochester, New York 14604 OViATT Buffalo, New York 14202
P 585.987.2800 F 585.454.3968 GILMAN P 716.248.3200 F 716.854.5100
Writer's Direct Dial Number: 585.987.2809 ATTORNEYS
Writer's Direct Fax Number: 585.445.2309 woodsoviatt.com
Email: aryan@woodsoviatt.com
June 27, 2022
VIA FIRST CLASS MAIL WITH ATTACHMENT
AND NYSCEF (LETTER ONLY)
Hon. Deborah Karalunas
Supreme Court of the State of New York
Onondaga County Courthouse
401 Montgomery Street
Syracuse, New York 13202
Re: Costello, Cooney & Fearon, PLLC vs. Melinda Burdick Bowe;
Index No.: 003917/2021
Dear Judge Karalunas:
Enclosed please rind Melinda Bowe's joint New York State and Federal tax returns with her
husband for 2020. All social security numbers, taxpayer identification numbers, and information
related to Ms. Bowe's husband's income has been redacted.
Pursuant to the Court's June 1 3, 2022 Order regarding Discovery Motions, this tax return is
being provided to the Court to review in camera, and is not being provided to Plaintiff. However, a
copy of this correspondence (without the tax return) is being filed in NYSCEF.
For the Court's ease of reference, i highlighted the amount of ordinary income listed on the
K-1 from the Plaintiff ($248,370) and the Section 179 deduction ($50,880). The product of those two
amounts is $196,595.00 ($248,370 — 50,880 = 196,595.00). That is the amount that is listed on line 5
of Schedule I to Ms. Bowe's federal tax returns (also highlighted for the Court's ease of reference)
and on line 11 of Ms. Bowe's New York State tax return (highlighted for the Court's reference).
Also included with this letter is a copy of the 1099-NEC form that was provided to Ms. Bowe
by the Plaintiff indicating that she was paid $3,750.00. The 1099 form represents the amount that
was paid to Ms. Bowe pursuant to the Of Counsel Agreement in 2020. That is the same amount that
is listed on Schedule 1, Line 3 in Ms. Bowe's federal tax return, and Line 6 of Ms. Bowe's New York
State tax return (all highlighted for the Court's reference). Thus, all income that was reported to
Ms. Bowe by Costello, Cooney & Fearon, PLLC in 2020 is recorded on her 2020 tax return.
Please note that Ms. Bowe and her husband have not yet tiled their 2021 tax returns. They
provided all information to their accountant to tile by April 15, but the accountant had a death in the
family shortly before the tax return was due to be tiled, and the accountant requested an extension for
that reason. Once that tax return is tiled, it will he provided to the Court.
889850:
The art of representing people
June 27, 2022
Page 2
If you have any questions about this please do not hesitate to contact me.
Respectfully submitted,
WOODS OVIATT GILMAN
Andrew J. Ryan
AJR/vat
Enclosure
cc: Melinda B. Bowe, Esq. (w/encl. via email)
;8898540: ; The art of representing people'
Document Filed Date
June 27, 2022
Case Filing Date
April 23, 2021
Category
Torts - Other (Unjust Enrichment/Convers)
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Preview
1900 Bausch & Lomb Place WOODS 1900 Main Place Tower Rochester, New York 14604 OViATT Buffalo, New York 14202 P 585.987.2800 F 585.454.3968 GILMAN P 716.248.3200 F 716.854.5100 Writer's Direct Dial Number: 585.987.2809 ATTORNEYS Writer's Direct Fax Number: 585.445.2309 woodsoviatt.com Email: aryan@woodsoviatt.com June 27, 2022 VIA FIRST CLASS MAIL WITH ATTACHMENT AND NYSCEF (LETTER ONLY) Hon. Deborah Karalunas Supreme Court of the State of New York Onondaga County Courthouse 401 Montgomery Street Syracuse, New York 13202 Re: Costello, Cooney & Fearon, PLLC vs. Melinda Burdick Bowe; Index No.: 003917/2021 Dear Judge Karalunas: Enclosed please rind Melinda Bowe's joint New York State and Federal tax returns with her husband for 2020. All social security numbers, taxpayer identification numbers, and information related to Ms. Bowe's husband's income has been redacted. Pursuant to the Court's June 1 3, 2022 Order regarding Discovery Motions, this tax return is being provided to the Court to review in camera, and is not being provided to Plaintiff. However, a copy of this correspondence (without the tax return) is being filed in NYSCEF. For the Court's ease of reference, i highlighted the amount of ordinary income listed on the K-1 from the Plaintiff ($248,370) and the Section 179 deduction ($50,880). The product of those two amounts is $196,595.00 ($248,370 — 50,880 = 196,595.00). That is the amount that is listed on line 5 of Schedule I to Ms. Bowe's federal tax returns (also highlighted for the Court's ease of reference) and on line 11 of Ms. Bowe's New York State tax return (highlighted for the Court's reference). Also included with this letter is a copy of the 1099-NEC form that was provided to Ms. Bowe by the Plaintiff indicating that she was paid $3,750.00. The 1099 form represents the amount that was paid to Ms. Bowe pursuant to the Of Counsel Agreement in 2020. That is the same amount that is listed on Schedule 1, Line 3 in Ms. Bowe's federal tax return, and Line 6 of Ms. Bowe's New York State tax return (all highlighted for the Court's reference). Thus, all income that was reported to Ms. Bowe by Costello, Cooney & Fearon, PLLC in 2020 is recorded on her 2020 tax return. Please note that Ms. Bowe and her husband have not yet tiled their 2021 tax returns. They provided all information to their accountant to tile by April 15, but the accountant had a death in the family shortly before the tax return was due to be tiled, and the accountant requested an extension for that reason. Once that tax return is tiled, it will he provided to the Court. 889850: The art of representing people June 27, 2022 Page 2 If you have any questions about this please do not hesitate to contact me. Respectfully submitted, WOODS OVIATT GILMAN Andrew J. Ryan AJR/vat Enclosure cc: Melinda B. Bowe, Esq. (w/encl. via email) ;8898540: ; The art of representing people'