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October 6, 2020
On May 1, 2020, Robert J. Smith, Esq. and his law firm of Costello, Cooney, & Fearon,
PLLC filed Notices of Appearance with the Court representing the following Defendants:
Jonathan Anderson, Jammie Blumer, Jason Cassalia, Joseph Ciciarelli, Eugene Conway, Michael
Dickinson, Roy Gratien and Joseph Peluso.
On September 24, 2020, a little over 4 months since Mr. Smith filed his Notice of
Appearance, he filed five (5) motions for dismissal of the complaint against the aforementioned
Defendants on the pleadings. On September 25, 2020, again a little over 4 months since Mr. Smith
filed his Notice of Appearance, he filed three (3) motions for dismissal of the complaint against
the aforementioned Defendants on the pleadings.
Plaintiffs counsel is also requesting a stay of any and all scheduling orders that are now in
place while we defend against these motions.
FAYETTEVILLE OFFICE
7030 EAST GENESEE STREET, SUITE 101
FAYETTEVILLE, NEW YORK 13066
PARRY & SMITH, L.L.C.
Case 5:18-cv-01218-GLS-CFH Document 106 Filed 10/06/20 Page 2 of 2
While I am not requesting a phone conference, if the Court would like to have one, I or in
partner can make ourselves available for such a conference.
Respectfully,
SMITH, ESQ.
JWS/
cc: Defense counsel via ECF