CHANG v. THE BANK OF NEW YORK MELLON CORPORATION et al

Filing 35

ORDER, re 34 letter request; notices for deposition deadline is extended 30 days. Fact deposition discovery is also extended 30 days; etc. Signed by Magistrate Judge Steven C. Mannion on 4/1/2019. (sms)

LAW OFFICES OF

WONG, WONG
RAYMOND H. WONG *
VALERIEY. C. WONG *

& ASSOCIATES, P.C.

150 BROADWAY, SUITE t588
NEW YORK, NY 10038
PHONE: [phone]
FACSIMILE: [phone]

ANTONY LEMBERSKY *
ROBERT JUN
NATALYA RUTCHYK *
EFRAIM S. LIPSCHUTZ

NEWJERSEY OFFICE
12 ROSZEL RD, STE AIO2
PRINCETON, NJ 08540
PHONE: [phone]
FACSIMILE: [phone]
*

MEMBER NY & NJ BARS
MEMBER NY BAR

March29, 2019
Magistrate Judge Steven C. Mannion
Martin Luther King Building
& U.S. Courthouse
50 Walnut Street
Newark, NJ 07101
Re:

Kenneth Chan a/k/a Kan Zhang v. The Bank of New York Mellon Corp., et al.
Civ. Action No.:
2:17-cv-11061
Status Letter

Dear Judge Mannion:
This firm represents Kenneth Chang a/k/a Kan Zhang (“Plaintiff’) in the above entitled
action. During the last telephone conference, Your Honor set deadlines on how the action is to
proceed. These included deadlines for notices ofdeposition to be sent out and when the depositions
are to be fmished. Plaintiff requests an extension of those deadlines because this Firm needs
additional time to review the ESI production of over 100,000 documents. While this is a small firm
and cannot dedicate all resources solely to this action, we reviewed approximately a fourth of the
production. Plaintiff needs more time-at least a month-beforej ticesfor4eoi1iin can be sent
out. This Firm spoke to counsel for Defendants who consentKor an extension of time. If the Court
wishes to set up another telephone conference, please let 5f’s Firm know.
Thank you for your attention to this matter.
t-

c

3D

for Plaint
/s/ Antony Lembersky
Antony Lembersky

cyt5 FC

3
C,

-

s/StnC. Mamion
Steven C. Mannion, U.$.M.J.
Da: