On May 27, 2021 a
Letter,Correspondence
was filed
involving a dispute between
Dolores Cortellessa Individually And As Executor Of The Estate Of Eugene Cortellessa,
Dolores Cortellessa
Individually And As Executor Of The Estate Of Eugene Cortellessa,
and
Abc Entities 1 Through 5,
Kenneth Schwartz M.D.,
St. Peter'S Health Partners,
St. Peter'S Health Partners Medical Associates, P.C.,
for Torts - Medical, Dental, or Podiatrist Malpractice
in the District Court of Saratoga County.
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Daniel P. Laraby
Direct Dial: 315.477.9900
dlaraby@pnhlawyers.com
NYSCEF
February 27, 2023
Honorable Richard A. Kupferman
Saratoga County Supreme Court
612 State Street
Schenectady, NY 12305
Re: Cortellessa v. Schwartz, et al.
Index No.: EF20211594
Dear Judge Kupferman:
We represent Plaintiff Dolores Cortellessa in the above-referenced action. Mrs. Cortellessa recently filed for
bankruptcy, and our firm has been appointed as special counsel to the bankruptcy trustee. We are in the
process of substituting the trustee as the proper party so that we may complete discovery.
In light of the delay caused by the bankruptcy filing, it has become necessary for us to request a ninety (90)
day extension to file the Note of Issue and complete depositions in this matter. As such, we respectfully
request that Your Honor extend the discovery deadlines as follows:
• Depositions to be completed by: 05/15/23
• Trial Note of Issue to be filed by: 05/28/23
If the forgoing meets with Your Honor’s approval, kindly “So Order” this letter below. We thank Your Honor
for your time and kind attention.
Very truly yours,
PORTER LAW GROUP
Daniel P. Laraby
DPL/ntf
So Ordered, this __ day of ________, 2023. __________________________________
Honorable Richard A. Kupferman
100 Madison Street, 15th Floor, Syracuse, N.Y. 13202-2725
Phone: 315.477.9900 Fax: 315.477.9923 www.pnhlawyers.com
Document Filed Date
February 27, 2023
Case Filing Date
May 27, 2021
Category
Torts - Medical, Dental, or Podiatrist Malpractice
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Daniel P. Laraby Direct Dial: 315.477.9900 dlaraby@pnhlawyers.com NYSCEF February 27, 2023 Honorable Richard A. Kupferman Saratoga County Supreme Court 612 State Street Schenectady, NY 12305 Re: Cortellessa v. Schwartz, et al. Index No.: EF20211594 Dear Judge Kupferman: We represent Plaintiff Dolores Cortellessa in the above-referenced action. Mrs. Cortellessa recently filed for bankruptcy, and our firm has been appointed as special counsel to the bankruptcy trustee. We are in the process of substituting the trustee as the proper party so that we may complete discovery. In light of the delay caused by the bankruptcy filing, it has become necessary for us to request a ninety (90) day extension to file the Note of Issue and complete depositions in this matter. As such, we respectfully request that Your Honor extend the discovery deadlines as follows: • Depositions to be completed by: 05/15/23 • Trial Note of Issue to be filed by: 05/28/23 If the forgoing meets with Your Honor’s approval, kindly “So Order” this letter below. We thank Your Honor for your time and kind attention. Very truly yours, PORTER LAW GROUP Daniel P. Laraby DPL/ntf So Ordered, this __ day of ________, 2023. __________________________________ Honorable Richard A. Kupferman 100 Madison Street, 15th Floor, Syracuse, N.Y. 13202-2725 Phone: 315.477.9900 Fax: 315.477.9923 www.pnhlawyers.com