On April 23, 2021 a
Exhibit,Appendix
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 01/13/2023 03:24 PM INDEX NO. 003917/2021
NYSCEF DOC. NO. 81 RECEIVED NYSCEF: 01/13/2023
EXHIBIT D
FILED: ONONDAGA COUNTY CLERK 01/13/2023 03:24 PM INDEX NO. 003917/2021
NYSCEF DOC. NO. 81 RECEIVED NYSCEF: 01/13/2023
From: Ryan, Andrew J.
Sent: Monday, November 15, 2021 11:13 AM
To: Paul G. Ferrara
Subject: CCF v. Bowe
PG,
I see that you filed an Amended Verified Complaint in the above case on November 11. Pursuant to CPLR
3025(a), the Plaintiff's time to amend the complaint without leave of court expired twenty days after the answer was
served. The Defendant does not consent to the Plaintiff amending the Compliant as it is plainly without merit, and
therefore, if you wish to amend your complaint, you will need to obtain leave of court.
I once again ask that you provide the Plaintiff's responses to our discovery demands that you are withholding
pending the execution of the Order for the Production and Exchange of Confidential Information, which was filed on
October 24, 2021.
Andy
Andrew J. Ryan, Esq.
Partner
Direct Dial: 585-987-2809
Direct Fax: 585-445-2309
Mobile: 585-402-5053
aryan@woodsoviatt.com
Firm Phone: 585-987-2800
Firm Fax: 585-454-3968
woodsoviatt.com
Visit our Covid-19 Resource Page
1
FILED: ONONDAGA COUNTY CLERK 01/13/2023 03:24 PM INDEX NO. 003917/2021
NYSCEF DOC. NO. 81 RECEIVED NYSCEF: 01/13/2023
1900 Bausch & Lomb Place, Rochester, New York 14604
A Member of MERITAS Firms Worldwide.
THE INFORMATION CONTAINED IN THIS COMMUNICATION IS CONFIDENTIAL, MAY BE SUBJECT TO THE ATTORNEY-CLIENT PRIVILEGE,
AND IS INTENDED ONLY FOR REVIEW AND USE BY THE ADDRESSEE. UNAUTHORIZED USE, DISCLOSURE OR COPYING OF THIS
COMMUNICATION OR ANY PART THEREOF IS STRICTLY PROHIBITED AND MAY BE UNLAWFUL. IF YOU HAVE RECEIVED THIS
COMMUNICATION IN ERROR, PLEASE DESTROY THIS COMMUNICATION, INCLUDING ALL ATTACHMENTS. PLEASE NOTIFY US
IMMEDIATELY BY RETURN E-MAIL OR CALL 585-987-2800.
2
Document Filed Date
January 13, 2023
Case Filing Date
April 23, 2021
Category
Torts - Other (Unjust Enrichment/Convers)
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Preview
FILED: ONONDAGA COUNTY CLERK 01/13/2023 03:24 PM INDEX NO. 003917/2021 NYSCEF DOC. NO. 81 RECEIVED NYSCEF: 01/13/2023 EXHIBIT D FILED: ONONDAGA COUNTY CLERK 01/13/2023 03:24 PM INDEX NO. 003917/2021 NYSCEF DOC. NO. 81 RECEIVED NYSCEF: 01/13/2023 From: Ryan, Andrew J. Sent: Monday, November 15, 2021 11:13 AM To: Paul G. Ferrara Subject: CCF v. Bowe PG, I see that you filed an Amended Verified Complaint in the above case on November 11. Pursuant to CPLR 3025(a), the Plaintiff's time to amend the complaint without leave of court expired twenty days after the answer was served. The Defendant does not consent to the Plaintiff amending the Compliant as it is plainly without merit, and therefore, if you wish to amend your complaint, you will need to obtain leave of court. I once again ask that you provide the Plaintiff's responses to our discovery demands that you are withholding pending the execution of the Order for the Production and Exchange of Confidential Information, which was filed on October 24, 2021. Andy Andrew J. Ryan, Esq. Partner Direct Dial: 585-987-2809 Direct Fax: 585-445-2309 Mobile: 585-402-5053 aryan@woodsoviatt.com Firm Phone: 585-987-2800 Firm Fax: 585-454-3968 woodsoviatt.com Visit our Covid-19 Resource Page 1 FILED: ONONDAGA COUNTY CLERK 01/13/2023 03:24 PM INDEX NO. 003917/2021 NYSCEF DOC. NO. 81 RECEIVED NYSCEF: 01/13/2023 1900 Bausch & Lomb Place, Rochester, New York 14604 A Member of MERITAS Firms Worldwide. THE INFORMATION CONTAINED IN THIS COMMUNICATION IS CONFIDENTIAL, MAY BE SUBJECT TO THE ATTORNEY-CLIENT PRIVILEGE, AND IS INTENDED ONLY FOR REVIEW AND USE BY THE ADDRESSEE. UNAUTHORIZED USE, DISCLOSURE OR COPYING OF THIS COMMUNICATION OR ANY PART THEREOF IS STRICTLY PROHIBITED AND MAY BE UNLAWFUL. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE DESTROY THIS COMMUNICATION, INCLUDING ALL ATTACHMENTS. PLEASE NOTIFY US IMMEDIATELY BY RETURN E-MAIL OR CALL 585-987-2800. 2