On May 12, 2022 a
Letter,Correspondence
was filed
involving a dispute between
Loancare, Llc,,
and
Donna De Freitas,
John De Freitas,
John Doe #1 Through John Doe #12,
The Last Twelve Names Being Fictitious And Unknown To Plaintiff, The Persons Or Parties Intended Being The Tenants, Occupants, Persons Or Corporations, If Any, Having Or Claiming An Interest In Or Lien Upon The Premises, Described In The Complaint,
for Real Property - Mortgage Foreclosure - Residential
in the District Court of Dutchess County.
Preview
FILED: DUTCHESS COUNTY CLERK 07/10/2023 04:22 PM INDEX NO. 2022-51497
NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 07/10/2023
THE LAW OFFICE OF
nI(~I\S. (;OWllm
18 FAIR STREET ADMITTED NY, CTIN
CARMEL, NEW YORK 10512 & D.C.
WASHINGTON
E-MAIL: rcowlelaw@comcast.net
WEB: rcowlelaw.com
TELEPHONE (845) 225-3026
FACSIMILE (845) 225-3027
July lO. 2023
Y.La..HYSCJ1E
Honorable Maria G. Rosa /' .
n Mana G. Rosa, J.S.C.
New York State Supreme Court Justice 3rtX Adjournment equest~
Dutchess County Chambers New Date: 7 :l r ;2 bk .
Failure To NOTIFY OPPOSING SIDE OR
lO Market Street
COUNSEL May Result In SANCTIONS
Poughkeepsie, New York 1260,1
'- 0ffo~;-h'o,,- k(. 7/11(/:13.
Re: Loancare, LLC v. Donna DeFreitas, et.a!. i<{.lJ Iv c!JAe 7/,111:z?, __~ /.
Ing~_~1:'J..Q.c..2_Q11: 5 1..1.9.1
f 1 /Ij.~~
. Michael It frascarelli, [sq.
Dear Judge Rosa: . Princip~' Court Attorney 10
• Han. M~ri~ G. ROSi, l.S.C.
We are the attorneys for Defendants, John -DeFreitas and DOllna DeFreitas
("Defendants"), in the above-captioned matter. My firm intends to file a Notice of
Appearance on behalf of the Defendants and wishes to file an Affirmation in Opposition to
Plaintiff's Motion' for Order of Reference and Default Judgment (Motion Seq. #1).
/
Having not been retained by the Defendants until latc Friday, 7,2023, we were
July
unable to meet the opposition deadline to Plaintiff's Motion of July 7,2023, as set forth in
the Court Notice dated .June 13,2023 (NYSCEF Doc No. 45). Accordingly, we request a
short extension of said deadline to Friday, July] 4,2023.
My office has reached out to Plaintiff's counsel,seeking their consent to such
adjournment but have not yet received a response.
1 of 1
Document Filed Date
July 10, 2023
Case Filing Date
May 12, 2022
Category
Real Property - Mortgage Foreclosure - Residential
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Preview
FILED: DUTCHESS COUNTY CLERK 07/10/2023 04:22 PM INDEX NO. 2022-51497 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 07/10/2023 THE LAW OFFICE OF nI(~I\S. (;OWllm 18 FAIR STREET ADMITTED NY, CTIN CARMEL, NEW YORK 10512 & D.C. WASHINGTON E-MAIL: rcowlelaw@comcast.net WEB: rcowlelaw.com TELEPHONE (845) 225-3026 FACSIMILE (845) 225-3027 July lO. 2023 Y.La..HYSCJ1E Honorable Maria G. Rosa /' . n Mana G. Rosa, J.S.C. New York State Supreme Court Justice 3rtX Adjournment equest~ Dutchess County Chambers New Date: 7 :l r ;2 bk . Failure To NOTIFY OPPOSING SIDE OR lO Market Street COUNSEL May Result In SANCTIONS Poughkeepsie, New York 1260,1 '- 0ffo~;-h'o,,- k(. 7/11(/:13. Re: Loancare, LLC v. Donna DeFreitas, et.a!. i<{.lJ Iv c!JAe 7/,111:z?, __~ /. Ing~_~1:'J..Q.c..2_Q11: 5 1..1.9.1 f 1 /Ij.~~ . Michael It frascarelli, [sq. Dear Judge Rosa: . Princip~' Court Attorney 10 • Han. M~ri~ G. ROSi, l.S.C. We are the attorneys for Defendants, John -DeFreitas and DOllna DeFreitas ("Defendants"), in the above-captioned matter. My firm intends to file a Notice of Appearance on behalf of the Defendants and wishes to file an Affirmation in Opposition to Plaintiff's Motion' for Order of Reference and Default Judgment (Motion Seq. #1). / Having not been retained by the Defendants until latc Friday, 7,2023, we were July unable to meet the opposition deadline to Plaintiff's Motion of July 7,2023, as set forth in the Court Notice dated .June 13,2023 (NYSCEF Doc No. 45). Accordingly, we request a short extension of said deadline to Friday, July] 4,2023. My office has reached out to Plaintiff's counsel,seeking their consent to such adjournment but have not yet received a response. 1 of 1