Kamburowski et al v. Kidd et al

Filing 41

Kamburowski et al v. Kidd et al

Doc. 41

VIA ECF and FIRST CLASS MAIL January 25, 2008 Honorable Carol B. Amon United States District Judge Eastern District of New York 225 Cadman Plaza East Brooklyn, New York 11201 Re: KAMBUROWSKI v. Kidd, No. 05-CV-0953 (CBA/RLM)

Dear Judge Amon: Please accept this letter as an application for reconsideration of your order of January 24, 2008, denying the Plaintiff's motion for extension of time to submit responsive papers to the Government's Motion for Summary Judgement. The Government's Motion for Summary Judgment which was filed in this matter on or about November 2, 2007, was filed after Defendant's counsel Mr. Steve Kim, was granted several extensions of time to submit a reply in this matter, all of which were graciously consented to by Plaintiff's counsel. The instant extension request has also been consented to by Defendant's counsel. Additionally, the attorney who has been handling this matter in our firm, Ms. Delli-Pizzi, has recently left our firm (this month), and consequently, I will personally be handling the completion of this matter, along with several other pressing matters with deadlines in January and early February. While I have spoken with Ms. Delli-Pizzi throughout this litigation, due to previously scheduled commitments in the nature of several Court appearances and Circuit Court brief deadlines in the months of January and February, I will need this additional time to become more familiar with this matter and properly respond to Defendant's motion. As such, I hereby respectfully request that you reconsider your January 24, 2008 decision, and grant the parties the following revised schedule:

Plaintiffs' Opposition Papers: Defendants' Reply Papers:

February 19, 2008 March 4, 2008

Dockets.Justia.com

In addition, I ask that the oral argument currently scheduled for February 21, 2008, be adjourned to a date after March 4, 2008. I have discussed this request with Assistant United States Attorney F. Franklin Amanat, and he has agreed to this extension of time and proposed schedule. Thank you for your time and consideration of this request.

Respectfully submitted, /s/ Michael P. DiRaimondo cc: F. Franklin Amanat Assistant U.S. Attorney