On March 30, 2023 a
Motion,Ex Parte
was filed
involving a dispute between
Leeann F. Giordano,
and
Macy'S,
Macy'S East Inc.,
Schindler Elevator Corporation,,
for Torts - Other (Premises)
in the District Court of Bronx County.
Preview
FILED: BRONX COUNTY CLERK 10/18/2023 03:14 PM INDEX NO. 805090/2023E
NYSCEF DOC. NO. 32 RECEIVED NYSCEF: 10/18/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF BRONX
-----------------------------------------------------------------x
LEEANN F. GIORDANO, Index No. 805090/2023E
Plaintiff, ATTORNEY AFFIRMATION
- against -
MACY’S EAST INC., MACY’S and
SCHINDLER ELEVATOR CORPORATION,
Defendants.
-----------------------------------------------------------------x
CATHERINE G. BRYAN, an attorney of law, duly licensed to practice in the State of New
York, hereby makes the following statements under the penalty of perjury:
1. I am a partner of the firm Connell Foley LLP, attorneys for defendants, Macy’s East
Inc., Macy’s, and Schindler Elevator Corporation (“Defendants”), in the above-captioned matter and
as such, I am fully familiar with the facts and circumstances surrounding this matter.
2. This Affirmation is submitted in response to Subin Associates, LLP’s Order to
Show Cause, moving to be relieved as counsel for plaintiff, Leeann Giordano (“plaintiff”).
3. Defendants do not oppose the Order Show Cause but do oppose the request for the
Court to grant an indefinite stay.
4. Defendants request the Court to limit any stay granted to forty-five (45) days.
Defendants contend forty-five (45) days is an appropriate and sufficient time frame for plaintiff to
retain new counsel, if she so chooses.
11952451-1
1 of 2
FILED: BRONX COUNTY CLERK 10/18/2023 03:14 PM INDEX NO. 805090/2023E
NYSCEF DOC. NO. 32 RECEIVED NYSCEF: 10/18/2023
Connell Foley LLP
Attorneys for Defendants,
Macy’s East Inc., Macy’s and Schindler Elevator
Corporation
By: ______________________________
Catherine G. Bryan, Esq.
One Newark Center
1085 Raymond Blvd., 19th Floor
Newark, New Jersey 07102
973.436.5800
Dated: October 18, 2023
TO: Peter May, Esq.
Subin Associates, LLP
150 Broadway – 23rd Floor
New York, New York, 10038
Attorneys for Plaintiff
11952451-1
2 of 2
Document Filed Date
October 18, 2023
Case Filing Date
March 30, 2023
Category
Torts - Other (Premises)
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FILED: BRONX COUNTY CLERK 10/18/2023 03:14 PM INDEX NO. 805090/2023E NYSCEF DOC. NO. 32 RECEIVED NYSCEF: 10/18/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX -----------------------------------------------------------------x LEEANN F. GIORDANO, Index No. 805090/2023E Plaintiff, ATTORNEY AFFIRMATION - against - MACY’S EAST INC., MACY’S and SCHINDLER ELEVATOR CORPORATION, Defendants. -----------------------------------------------------------------x CATHERINE G. BRYAN, an attorney of law, duly licensed to practice in the State of New York, hereby makes the following statements under the penalty of perjury: 1. I am a partner of the firm Connell Foley LLP, attorneys for defendants, Macy’s East Inc., Macy’s, and Schindler Elevator Corporation (“Defendants”), in the above-captioned matter and as such, I am fully familiar with the facts and circumstances surrounding this matter. 2. This Affirmation is submitted in response to Subin Associates, LLP’s Order to Show Cause, moving to be relieved as counsel for plaintiff, Leeann Giordano (“plaintiff”). 3. Defendants do not oppose the Order Show Cause but do oppose the request for the Court to grant an indefinite stay. 4. Defendants request the Court to limit any stay granted to forty-five (45) days. Defendants contend forty-five (45) days is an appropriate and sufficient time frame for plaintiff to retain new counsel, if she so chooses. 11952451-1 1 of 2 FILED: BRONX COUNTY CLERK 10/18/2023 03:14 PM INDEX NO. 805090/2023E NYSCEF DOC. NO. 32 RECEIVED NYSCEF: 10/18/2023 Connell Foley LLP Attorneys for Defendants, Macy’s East Inc., Macy’s and Schindler Elevator Corporation By: ______________________________ Catherine G. Bryan, Esq. One Newark Center 1085 Raymond Blvd., 19th Floor Newark, New Jersey 07102 973.436.5800 Dated: October 18, 2023 TO: Peter May, Esq. Subin Associates, LLP 150 Broadway – 23rd Floor New York, New York, 10038 Attorneys for Plaintiff 11952451-1 2 of 2