Equal Employment Opportunity Commission v. Kelley Drye & Warren, LLP

Filing 46

ENDORSED LETTER addressed to Magistrate Judge Michael H. Dolinger from Jeffrey Burstein, dated 4/22/2011, re: At the end ofthe April 13, 2011 conference before Your Honor concerning discovery issues raised by Plaintiff EEOC, Defendant raised an issue that had not been the subject of a pre-motion letter, its request for time logs and records Mr. D'Ablemont kept regarding his work for his clients Cox Reps, TeleRep and HRP for a ten-year period. Your Honor stated that EEOC should respond to this request by April 27, 2011. EEOC does not possess these documents; and Mr. D'Ablemont has stated that given the very lengthy time frame of this request, ten years, he will need an additional week to be able to gather and review these documents. Therefore, if Your Honor approves, by May 5, 2011 either EEOC will produce the documents to Defendant; or alternatively (as Your Honor allowed in response to my inquiry at the April 13, 2011 proceeding), Mr. D'Ablemont will move to quash by that date. Defendant has consented to this one-week extension. ENDORSEMENT: Application granted. (Signed by Magistrate Judge Michael H. Dolinger on 4/22/2011) (lnl)

Apr 22 2011

3:04PM

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April 22, 2011
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APR 2 2 2011

Han. Michael H. Dolinger, U.S.M.J.
United States District Court
Southern District ofNew York
500 Pearl Street
New York. N.Y. 10007-1312

Re; Bgual Employment Opportunity Commission v. Kel1ey POre & Warren LLP, 1O-CY-0655
(LTS) (MHD)
Dear Magistrate Judge Dolinger:
At the end of the April 13) 2011 conference before Your Honor concerning discovery
issues raised by Plaintiff EEOC, Defendant raised an issue that had not been the subject of a pre­
motion 1ettert its request for time logs and records Mr. D'Ablemont kept regarding his work for
his clients Cox Reps~ Te1eRep and HRP for a ten-year period. Your Honor stated that EEOC
should respond to this request by April 27, 20] 1. EEOC does not possess these documents; and
Mr. D'Ablemont has stated that given the very lengthy time frame of this request~ ten years~ he
will need an additional week to be able to gather and review these documents. Therefore, if Your
Honor approves, by May 5, 20] 1 either EEOC will produce the documents to Defendant; or
alternatively (as Your Honor allowed in response to my inquiry at the April 13, 2011 proceeding)~
!vir. D'Ablemont will move to quash by that date. Defendant has consented to this one-week
extension.
.
Thank you for

YOUI'

Honor's cousideration of this matter.

Respectfully submitted,

)/b/~
Jeffrey Burstein
cc: Bettina B. Plevan, Esq. (bye-mail)
Joseph C. O'Keefe, Esq. (bye-mail)