`NYSCEF DOC. NO. 31
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`INDEX NO. 2023-5539
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`RECEIVED NYSCEF: 03/15/2024
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`2000 Market Street, Suite 1300
`Philadelphia, PA 19103
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`March 15, 2024
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`Supreme Court – Chemung County
`203-209 William Street
`P.O. Box 588
`Elmira, NY 14902
`Attn: Hon. Christopher P. Baker
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`T(215) 972-7900
`F(215) 564-7699
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`Direct Dial: (267) 765-4123
`Email: jwescoe@wglaw.com
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`RE: Capreece Moore v. J.B. Hunt Transport, Inc., et al.
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`Supreme Court of the State of New York, County of Chemung
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`Index NO. 2023/5539
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`Your Honor:
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`This office represents defendants J.B. Hunt Transport, Inc., Costco Wholesale
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`Corporation, and Duke Hur (“responding defendants”). On March 14, 2024, counsel for plaintiff,
`Capreece Moore, filed a letter to Your Honor, alleged that responding defendants failed to
`respond to plaintiff’s Post Deposition Demands, and requested that Your Honor schedule a
`conference and/or issue an order directing defendants’ discovery compliance. We write in
`response to said March 14, 2024 letter.
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`Plaintiff failed to note that, on January 17, 2024 at 12:45 p.m., responding defendants
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`served their responses to plaintiff’s Post Deposition Demands with an accompanying 42-page
`document production. See Exhibit A attached hereto. As seen in the attached document,
`Plaintiff’s assertion that the “deadline passed without any discovery being produced” is wholly
`inaccurate. Therefore, Plaintiff’s request that Your Honor schedule a conference and/or issue an
`order is moot.
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`JAW/mdp
`Attachment (Exhibit A)
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`Thank you very much for Your Honor’s attention to this matter.
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`Respectfully submitted,
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`/s/ James A. Wescoe
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`James A. Wescoe
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`Weber Gallagher Simpson Stapleton Fires & Newby LLP | www.wglaw.com
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