Kamburowski et al v. Kidd et al
Filing
19
Letter requesting extension of time to complete fact discovery by Michael Kamburowski, Gina Kamburowski. (DiRaimondo, Michael)
Kamburowski et al v. Kidd et al
Doc. 19
DIRAIMONDO & MASI, LLP
ATTORNEYS AT LAW
4 0 1 BR O AD H OL L O W ROAD, #302 M E L V I L L E, NE W YORK 11747 ( 6 3 1 ) 777-5557 F A X (631) 777-5114
BY FEDERAL EXPRESS September 26, 2006 Honorable Roanne Mann Unit ed States Magistrate Judge United States Courthouse Eastern District of New York 225 Cadman Plaza East Brooklyn, New York 11201 Re: Kamburowski v. Kidd, CV-05-953
Dear Magistrate Mann: The Plaintiffs respectfully request an extension of time, until January 30, 2007, to complete fact discovery in this matter. The parties are currently in the middle of depositions, and have depositions scheduled for the first week of October. After these depositions, we still have approximately four depositions remaining, and therefore, need the additional time to complete this process. Once the depositions have been completed we hope to engage in settlement negotiations concerning the possible resolution of this matter, and believe that the additional time in this regard is also necessary. The Defendants have, of course, consented to this request. Thank you for your time and consideration of this request. Very truly yours,
Michael P. DiRaimondo MPD/ cc: Steve Kim, Esq.
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