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  • Catherine Stramba v. Michael AyersTorts - Motor Vehicle document preview
  • Catherine Stramba v. Michael AyersTorts - Motor Vehicle document preview
						
                                

Preview

FILED: TOMPKINS COUNTY CLERK 05/11/2021 03:41 PM INDEX NO. EF2021-0016 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 05/11/2021 CI2021-07828 Index # : EF2021-0016 LAW OFFICE OF J. WILLIAM SAVAGE ATTORNEYS AND SUPPORT STAFF ARE EMPLOYEES OF GOVERNMENT EMPLOYEES INSURANCE COMPANY 6320 Fly Road, Suite 107 East Syracuse, NY 13057 Telephone: 315-446-4705 Fax: 315-446-4715 May 11, 2021 NYSCEF Honorable Joseph R. Cassidy Tompkins County Courthouse 320 North Tioga Street Ithaca, New York 14851 RE: Stramba v. Ayers Index No.: EF2021-0016; R.J.I. No.: 2021-0126-C Claim No.: 0677796740000001 Our File No.: 21-0020566 Dear Judge Cassidy: As you may know, our office represents the Defendant, Michael Ayers, regarding the above-referenced matter. If Your Honor is agreeable may we respectfully request a short conference to address ongoing discovery issues? We continue to await plaintiff’s medical records with the exception of Guthrie Medical, as well as authorizations to obtain our own records, which plaintiff does not want to provide for some reason. Plaintiff has disclosed numerous other treating providers to include: Emergency Medical Associates of Cayuga; Bangs Ambulance; Radiology Associates of Ithaca; Ithaca Family Practice; Urgent Care – Cortland; and Edward Mills, MD. Additionally, plaintiff seems to think she’s entitled to my client’s driver’s abstract and cell phone records, which we of course dispute, even assuming my client has possession of such documents. These ongoing disputes have led to the cancellation of depositions scheduled for May 14, 2021. Thank you for your consideration in this regard. Respectfully yours, J. William Savage, Esq. cc: Luciano L. Lama, Esq. Sensitivity: Confidential