On August 01, 2018 a
Letter,Correspondence
was filed
involving a dispute between
Amanda Dillon,
Valerie Austin,
and
Brian Changlai Md,
Jeanne Bishop Md,
Ovid Neulander Md,
Pawan K Rao Md,
for Torts - Medical, Dental, or Podiatrist Malpractice
in the District Court of Onondaga County.
Preview
GALE GALE & HUNTLLC
ATTORNEYS AT LAW
Catherine A. Gale
*
Paralegals
Max D. Gale Olga S. Camperlino
Kevin T. Hunt Leslie A. Miller
Matthew J. Van Beveren Corrine M. Scoville
Kirsten Lerch Kroft
Andrew P. Borelti Office Manager
Katherine A. Buckley Jo Ann Stuhler
Minla Kim Street Address Mailing Address
Christine A. Sullivan 7136 East Genesee Street P0 Box 97
Robert P. Carpenter Fayetteville, NY 13066 Fayetteville. NY 13066-0097
Kali P. Schreiner
*
Also Admitted in PA Tel 315-637-3663 Fax 315-637-3667
www.gghlawoffice.com
August 16, 2022
VIA NYSCEF
Honorable Joseph E. Lamendola, J.S.C.
Onondaga County, Supreme Court
401 Montgomery Street
Syracuse, New York 13202
RE: Austin v Bishop, et a!
Index No.: 007476/2018
Dear Judge Lamendola:
I write with respect to the pending motions for sunmiary judgment filed by Defendants
Bishop, Rao, Changlai, and Neulander.
My office, having never asked for an extension to the applicable deadline, filed a motion
for summary judgment on behalf of Dr. Bishop on March 8, 2022. As a matter professional
courtesy, my office did not object to plaintiffs' request for additional time to file opposition papers.
Accordingly, Plaintiffs had five months to prepare their opposition papers.
Plaintiffs' opposition to Dr. Bishop's motion contains two expert affidavits, a
memorandum of law, and attorney affidavit, totaling over 75 pages. Moreover, the medical records
relevant to this motion greatly exceed 1,000 pages. Given the sheer enormity of the pending
motions, I respectfully request that the deadline to file reply papers for the pending motions be
adjourned two weeks from August 23, 2022, to September 6, 2022.
I have conferred with plaintiffs' attorney and co-defendant counsel and both have agreed
to the adjournment. If this meets with your approval, I respectfully request that you So Order this
correspondence.
Thank you for your attention to this matter.
SO ORDERED
Hon. Joseph E. Lamendola
Respectfully Submitted,
GALE GALE & HUNT, LLC
Robert P. Carpenter
rcarpentergghlawoffice.com
CAG/
CC: Matthew Whritenour, Esq.
Zachary Mattison, Esq.
Document Filed Date
August 16, 2022
Case Filing Date
August 01, 2018
Category
Torts - Medical, Dental, or Podiatrist Malpractice
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GALE GALE & HUNTLLC ATTORNEYS AT LAW Catherine A. Gale * Paralegals Max D. Gale Olga S. Camperlino Kevin T. Hunt Leslie A. Miller Matthew J. Van Beveren Corrine M. Scoville Kirsten Lerch Kroft Andrew P. Borelti Office Manager Katherine A. Buckley Jo Ann Stuhler Minla Kim Street Address Mailing Address Christine A. Sullivan 7136 East Genesee Street P0 Box 97 Robert P. Carpenter Fayetteville, NY 13066 Fayetteville. NY 13066-0097 Kali P. Schreiner * Also Admitted in PA Tel 315-637-3663 Fax 315-637-3667 www.gghlawoffice.com August 16, 2022 VIA NYSCEF Honorable Joseph E. Lamendola, J.S.C. Onondaga County, Supreme Court 401 Montgomery Street Syracuse, New York 13202 RE: Austin v Bishop, et a! Index No.: 007476/2018 Dear Judge Lamendola: I write with respect to the pending motions for sunmiary judgment filed by Defendants Bishop, Rao, Changlai, and Neulander. My office, having never asked for an extension to the applicable deadline, filed a motion for summary judgment on behalf of Dr. Bishop on March 8, 2022. As a matter professional courtesy, my office did not object to plaintiffs' request for additional time to file opposition papers. Accordingly, Plaintiffs had five months to prepare their opposition papers. Plaintiffs' opposition to Dr. Bishop's motion contains two expert affidavits, a memorandum of law, and attorney affidavit, totaling over 75 pages. Moreover, the medical records relevant to this motion greatly exceed 1,000 pages. Given the sheer enormity of the pending motions, I respectfully request that the deadline to file reply papers for the pending motions be adjourned two weeks from August 23, 2022, to September 6, 2022. I have conferred with plaintiffs' attorney and co-defendant counsel and both have agreed to the adjournment. If this meets with your approval, I respectfully request that you So Order this correspondence. Thank you for your attention to this matter. SO ORDERED Hon. Joseph E. Lamendola Respectfully Submitted, GALE GALE & HUNT, LLC Robert P. Carpenter rcarpentergghlawoffice.com CAG/ CC: Matthew Whritenour, Esq. Zachary Mattison, Esq.