On September 16, 2022 a
Letter,Correspondence
was filed
involving a dispute between
Wells Fargo Bank Na,
and
City Of Cortland,
Doe John,
Timothy J Stramba,
for Real Property - Mortgage Foreclosure - Residential
in the District Court of Cortland County.
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500 Bausch & Lomb Place
Rochester, NY 14604 P 855-227-5072
F 585-454-0302
ATTORNEYS
woodsdefaultservices.com
Attorney's Email: sframe@woodsdefaultservices.com
June 14, 2023
via NYSCEF
Cortland County Supreme Court
Attn: Hon. Mark G Masler
46 Greenbush Street, Suite 301
Cortland, NY 13045
Re: Wells Fargo Bank, N.A., etc. v. Timothy J. Stramba,. et al.
Index No.: EF22-400
Dear Justice Masler:
Plaintiff is aware of the upcoming deadline to file our motion for Default Judgment and
for an Order of Reference. Please be advised that this file has been on a client directed hold so
the client can review the loan for loss mitigation options and additional elevated internal
research. The client has just contact our office earlier today authorizing us to prepare and file a
motion for the order of reference. As such, our office is respectfully requesting that the court
grant plaintiff an adjournment of 30-60 days in which to file our motion for an order of reference
in order for us to obtain the necessary Affidavit of Merit from the client, and subsequently draft
and file our motion.
105334-1
2023340672 EF22-400
06/14/2023 04:55:36 PM
Pages 2
E zabe h La k n un y le k
Please call Stuart Frame at 855-227-5072 to confirm that this adjournment has been
granted. Thank you for your attention and consideration in this matter.
Sincerely,
Woods Oviatt Gilman LLP
Stuart P. Frame, Esq.
Attorney for Plaintiff
SF/spf
105334-1
Document Filed Date
June 14, 2023
Case Filing Date
September 16, 2022
Category
Real Property - Mortgage Foreclosure - Residential
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500 Bausch & Lomb Place Rochester, NY 14604 P 855-227-5072 F 585-454-0302 ATTORNEYS woodsdefaultservices.com Attorney's Email: sframe@woodsdefaultservices.com June 14, 2023 via NYSCEF Cortland County Supreme Court Attn: Hon. Mark G Masler 46 Greenbush Street, Suite 301 Cortland, NY 13045 Re: Wells Fargo Bank, N.A., etc. v. Timothy J. Stramba,. et al. Index No.: EF22-400 Dear Justice Masler: Plaintiff is aware of the upcoming deadline to file our motion for Default Judgment and for an Order of Reference. Please be advised that this file has been on a client directed hold so the client can review the loan for loss mitigation options and additional elevated internal research. The client has just contact our office earlier today authorizing us to prepare and file a motion for the order of reference. As such, our office is respectfully requesting that the court grant plaintiff an adjournment of 30-60 days in which to file our motion for an order of reference in order for us to obtain the necessary Affidavit of Merit from the client, and subsequently draft and file our motion. 105334-1 2023340672 EF22-400 06/14/2023 04:55:36 PM Pages 2 E zabe h La k n un y le k Please call Stuart Frame at 855-227-5072 to confirm that this adjournment has been granted. Thank you for your attention and consideration in this matter. Sincerely, Woods Oviatt Gilman LLP Stuart P. Frame, Esq. Attorney for Plaintiff SF/spf 105334-1