Small v. New York City Department of Correction et al

Filing 284

ORDER granting 280 Letter Motion for Extension of Time to File. Application granted. (Signed by Judge Ronnie Abrams on 4/15/2020) (rj)

THE CITY OF NEW YORK

LAW DEPARTMENT

JAMES E. JOHNSON
Corporation Counsel

DANIEL G. SAAVEDRA
Senior Counsel
phone: [phone]
fax: [phone]
e-mail: [e-mail]

100 CHURCH STREET
NEW YORK, NY 10007

April 14, 2020
BY ECF
Honorable Ronnie Abrams
United States District Court
Southern District of New York
500 Pearl Street
New York, NY 10007
Re:

Samuel Small v. City of New York, et al., 09 Civ. 1912 (DAB)(SDA)

Your Honor:
I am a Senior Counsel in the Office of James E. Johnson, Corporation Counsel for the
City of New York, and the attorney assigned to the defense of the above-referenced matter. The
parties write to respectfully request an extension of time to submit certain pre-trial submissions
presently due on April 15, 2020.
By way of background, plaintiff Samuel Small alleges that the defendants violated his
constitutional rights on three occasions while he was a New York City Department of Correction
(“DOC”) detainee. On March 27, 2020, the Court endorsed the parties proposed deadlines for
pretrial filings. See Docket Entry No. 279.
Since that time, the parties have endeavored to craft joint filings pursuant to the Court’s
Individual Rules and Practices. However, the current public health crisis and the attendant social
distancing requirements have slowed this process. The parties, therefore, respectfully request
permission to file the following documents on April 22, 2020: the Joint Pre-Trial Statement, the
Joint Proposed Voir Dire, the Joint Proposed Jury Charge, and the Joint Proposed Verdict Sheet.
The parties anticipate filing motions in limine on April 15, 2020 and responding to the same by
May 6, 2020, in accordance with the previously agreed upon schedule. As such, this extension of
time should not impact any other deadlines in this matter.

Defendants thank the Court for its consideration of this request.
Respectfully submitted,

_________________________
Daniel Guillermo Saavedra
Senior Counsel
cc:

BY ECF
Counsel for Plaintiff

Application granted.
SO ORDERED.
_________________
Hon. Ronnie Abrams
4/15/2020

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