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  • Costello, Cooney & Fearon, Pllc v. Melinda Burdick BoweTorts - Other (Unjust Enrichment/Convers) document preview
  • Costello, Cooney & Fearon, Pllc v. Melinda Burdick BoweTorts - Other (Unjust Enrichment/Convers) document preview
						
                                

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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 LLP Writer's Direct Dial Number: 585.987.2809 Writer's Direct Fax Number: 585.445.2309 ATTORNEYS Email: aryan@woodsoviattcom woodsoviatt.com July 6, 2022 VIA NYSCEF AND FIRST CLASS MAIL Hon. Deborah H. 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: I represent the Defendant in the above matter, Melinda Burdick Bowe, and I write with a joint request of the parties for an extension of the Preliminary Conference Order that was issued by the Court on November 10, 2021. As the Court is aware, there were recent discovery motions in this case which has resulted in some delay. I conferred with Mr. Rose, on behalf of the Plaintiff, and in comparing our vacation and work schedules, we ask that the Court amend the following dates on the Preliminary Conference Scheduling Order: 1. All depositions to be completed no later than October 21, 2022; 2. Trial Note of Issue and Certificate of Readiness to be filed on or before November 30, 2022. If this change is acceptable to the Court, Ihave provided a SO ORDERED line at the bottom of this letter. Respectfully submitted, WOODS OVIATT GILMAN LLP Andrew J. Ryan AJR/ps cc: Melinda B. Bowe, Esq. (via email) SO ORDERED. Hon. Deborah H. Karalunas, JSC Dated: July , 2022 The art of representing people 8907942: )