Davis v. Kirkpatrick & Lockhart L.L.P.
Filing
7
FILING ERROR - ELECTRONIC FILING FOR NON-ECF DOCUMENT - MOTION for Extension of Time to Complete Discovery. Document filed by Jamal Davis. (Eze, Chidi) Modified on 6/8/2005 (gf, ).
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Davis v. Kirkpatrick & Lockhart L.L.P.
Doc. 7
Case 1:04-cv-09195-RPP
Document 7
Filed 06/07/2005
Page 1 of 2
Law Offices of
Gary Newlin Rawlins
310 Livingston Street Brooklyn, New York 11217
...
Telephone: (718) 855 3005
June 7, 2005 The Honorable Robert P. Patterson, Jr. United States District Judge Southern District of New York 500 Pearl Street New York, NY 10007-1312
Re:
Davis v. Kirkpatrick & Lockhart LLP 04-CV- 9195 (RPP)
Dear Judge Patterson: I am a co-counsel for Plaintiff in the above-referenced claim of employment discrimination on the basis of race. I write to respectfully request that the Court grant Plaintiff a sixty day enlargement of time to and including August 20, 2005 to complete his discovery of this case, for the below stated reasons. The present discovery deadline is June 20, 2005. The undersigned co-counsel was retained by Plaintiff on April 6, 2005, and after a review of the case, I noted that Plaintiff's Complaint needed to be better pleaded. The defendant refused to consent to the amendment, thus Plaintiff was compelled to file a motion to amend his pleadings. That motion is still pending before Your Honor. Further, a review of the entire Plaintiff's case, revealed that Plaintiff will need to depose at least seven (7) employees of the defendant company to be ready for the trial of this case. Those depositions are still being arranged as the needs of all the parties is a factor to consider in setting the dates for said deposition. I have conferred with the defense counsel and they have no objection to this request. No previous request to extent the discovery deadline in this case has been made. Accordingly, Plaintiff humbly request that the discovery deadline be extended to and including August 20, 2005. I thank Your Honor for considering this request. Respectfully Submitted GARY N. RAWLINS ESQ.
Dockets.Justia.com
Case 1:04-cv-09195-RPP
Document 7
Filed 06/07/2005
Page 2 of 2
By
/s/ Chidi Eze, Esq. (CE-4333) 310 Livingston Street Brooklyn, NY 11217
cc:
Justin Y.K. Chu Pollack & Kaminsky 114 West 47th Street New York, NY 10036
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