Kamburowski et al v. Kidd et al

Filing 17

Kamburowski et al v. Kidd et al

Doc. 17

U.S. Department of Justice

United States Attorney Eastern District of New York
SLR:SJK 2005V00371 One Pierrepont Plaza Brooklyn, New York 11201 Mailing Address: 147 Pierrepont Street Brooklyn, New York 11201

June 28, 2006 FILED ELECTRONICALLY Honorable Roanne L. Mann United States Magistrate Judge Eastern District of New York 225 Cadman Plaza East Brooklyn, New York 11201 Re: Kamburowski v. Kidd, No. CV-05-0953 (CBA)(RLM)

Dear Judge Mann: Defendants in the above-referenced matter respectfully request an extension of time of sixty days, to September 29, 2006, to complete fact discovery. An extension is necessary because of difficulties in contacting witnesses and scheduling them for depositions. For instance, the undersigned has not been able to reach one fact witness who has retired since the underlying events in this matter. Another fact witness will be on a temmporary duty assignment in Connecticut for most of July, and another fact witness has been permanently reassigned to Miami, Florida. Further, the undersigned will be on annual leave for first week in July. Currently, the fact discovery deadline is July 24, 2006. This is Defendants' second request for an extension in this case. The Court granted Defendants' first request, for an extension to respond to the complaint, on April 18, 2005, and counsel for Plaintiffs have consented to this request. Respectfully submitted, ROSLYNN R. MAUSKOPF United States Attorney By: \s\ Steven Kim Steven Kim (SK6445) Assistant U.S. Attorney [phone]

cc:

Michael P. DiRaimondo, Esq. Mary Elizabeth Delli-Pizzi, Esq. DiRaimondo & Masi, LLP 401 Broadhollow Road, Suite 302 Melville, New York 11747
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