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Honorable Francis A. Nicolai

Putnam County Supreme Court

20 County Center
Cannd, New York 10512

RE: Mario Caruso v. Jennifer &Bumgarner, et a]

Index No.: 122/2012
Your Honor.

Please allow this to confirm that mis office represents both William 0. Sayegh,
Esq and The Law Firm of William O Sayegh, PC in connection with me abovereferenced matter

I am submitting this correspondence m response to Plaintiff's counsel's fix to

Chambers earlier today As a part of plaintiff's fix tothe Court, (which was m response to James A Randazzo's request on behalfofhis clients for thirty (30) days to permit new
counsel to appear), a six (6) page letter dated November IS, 2011, was submitted to the

Court This unsworn and unverified letter had not previously been disclosed, but more
importantly, was not submitted by Plaintiff's counsel m opposition to defendants' CPLR 3211 Motion to Dismiss mat was returnable and fully submitted this f"OTpfag Therefore,
it should notbe considered by the Court

Since our CPLR 3211 motion was fully submitted today and we are not
requesting an adjournment, we oppose me issuance by the Court of a Temporary

Restraining Order, which would any way relate to William 0. Sayegh, Esq and/or The LawFirm ofWilliam0. Sayegh, P C.
Further, no facts have been presented to this Court which would warrant a reversal ofits initial denial of plaintiffs request foraTemporary Restraining Order. If

Continued

good

DJ'nso^BS o TOTTTTfi

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Page 2

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We have no oppootion to the adjournment guested by James ARandan, Esq 'und^f t0 ** and SlT'3 8llegatl0nfl mta Februaiy 24. 2012 letterMr of underlying ^^ conflicts 5 of interest wrongdoing within the "SheriffsPercent
proceedings, that in the past Spain &Spain also represented the current Sheriff, coemployees of the Sheriff and the County of Putnam, thereby making has current
representation of Mano Caruso and criticisms of the Sheriffs Department wholly
inappropriate. Therefore, Spain &Spain has a conflict of interest mthe instant plenary
action and Order to Show Cause.

Spun once again misleads the court by failing to reveal that he served as Confidential Advisor to the Sheriff while at the same representing Mario Curuso in the cnminal

Accordingly, it is necessary that the parties' directly effected by Spam & Spain's
conflict of interesthave ample tunc in order to obtain separaterepresentation

Thank you foryour kind consideration

RespecAJly submitted,
Rones, Esq

TheLaw Firm ofWilliam G.Sayegh, P.C.

cc James ARandazzo.Esq (via facsimile 914-288-0850)

Spam &Spam (via facsimile 845-628-0694)

cEhan I Fusco, LLC (via facsimile 973-618-9772)

Sayegh Law
THE LAW tlRM OF W1UIAM G SAYEGH, PC
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