On September 21, 2015 a
Letter,Correspondence
was filed
involving a dispute between
Lisa Birch,
Lynn Ammirato,
and
Anna Marie Sochurek,
for Tort
in the District Court of Westchester County.
Preview
DELBELLO DONNELLAN WEINGARTEN
WISE & WIEDERKEHR, LLP
Alfred E. Donnellan COUNSELLORS AT LAW Connecticut Office
1111 SUMMER STREET
Partner STAMFORD, CT 06905
aed@ddw-law.com THE GATEWAY BUILDING (203) 219-9896
ONE NortH LEXINGTON AVENUE
WHITE PLAINS, NEW YORK 10601
(914) 681-0200
FACSIMILE (914) 684-0288
March 14, 2016
Via NYSCEF and Hand Delivery
Hon. Sam D. Walker
Westchester County Supreme Court
111 Dr. Martin Luther King Jr. Blvd.
White Plains, New York 10601
Re: Lynn Ammirato and Lisa Birch vs. Anna Marie T. Sochurek
Westchester County Index No. 65411/2015
Dear Justice Walker:
We represent Defendant Anna Marie T. Sochurek in the above-referenced action. We
write in connection with the letter filed by Plaintiffs on March 11, 2016, which improperly
submits legal arguments in connection with a motion that has been fully submitted since October
28, 2015 in contravention of your Honor’s Part Rules.
Plaintiffs filed a post-submission letter mischaracterizing an Order issued by the
Surrogate’s Court in Dutchess County dated March 8, 2016 and rearguing Plaintiffs’ motion,
which we respectfully request should not be read or considered by this Court pursuant to Section
II, paragraph N of your Honor’s Part Rules. We will not address directly Plaintiffs incorrect legal
arguments as they were addressed fully in our motion papers. However, we point out that Ms.
Ammirato’s and Ms. Birch’s motion to dismiss the construction proceeding was not granted, the
proceeding is still pending, and Surrogate James D. Pagones adjourned the matter until June 16,
2016 for counsel to submit a written status update with that Court.
In the event that you Honor wishes to consider Plaintiffs’ letter filed on March 11, 2016,
we would request an opportunity to respond.
Very truly yours, 4
C fg Jp
tig
d x
Alfred E. Donne Han
cc: Robert G. Edmonds, Esq., and Neil G. Marantz, Esq. (By NYSCEF)
lof 1
Document Filed Date
March 14, 2016
Case Filing Date
September 21, 2015
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Preview
DELBELLO DONNELLAN WEINGARTEN WISE & WIEDERKEHR, LLP Alfred E. Donnellan COUNSELLORS AT LAW Connecticut Office 1111 SUMMER STREET Partner STAMFORD, CT 06905 aed@ddw-law.com THE GATEWAY BUILDING (203) 219-9896 ONE NortH LEXINGTON AVENUE WHITE PLAINS, NEW YORK 10601 (914) 681-0200 FACSIMILE (914) 684-0288 March 14, 2016 Via NYSCEF and Hand Delivery Hon. Sam D. Walker Westchester County Supreme Court 111 Dr. Martin Luther King Jr. Blvd. White Plains, New York 10601 Re: Lynn Ammirato and Lisa Birch vs. Anna Marie T. Sochurek Westchester County Index No. 65411/2015 Dear Justice Walker: We represent Defendant Anna Marie T. Sochurek in the above-referenced action. We write in connection with the letter filed by Plaintiffs on March 11, 2016, which improperly submits legal arguments in connection with a motion that has been fully submitted since October 28, 2015 in contravention of your Honor’s Part Rules. Plaintiffs filed a post-submission letter mischaracterizing an Order issued by the Surrogate’s Court in Dutchess County dated March 8, 2016 and rearguing Plaintiffs’ motion, which we respectfully request should not be read or considered by this Court pursuant to Section II, paragraph N of your Honor’s Part Rules. We will not address directly Plaintiffs incorrect legal arguments as they were addressed fully in our motion papers. However, we point out that Ms. Ammirato’s and Ms. Birch’s motion to dismiss the construction proceeding was not granted, the proceeding is still pending, and Surrogate James D. Pagones adjourned the matter until June 16, 2016 for counsel to submit a written status update with that Court. In the event that you Honor wishes to consider Plaintiffs’ letter filed on March 11, 2016, we would request an opportunity to respond. Very truly yours, 4 C fg Jp tig d x Alfred E. Donne Han cc: Robert G. Edmonds, Esq., and Neil G. Marantz, Esq. (By NYSCEF) lof 1