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

Filing 94

ENDORSED LETTER addressed to Magistrate Judge Michael H. Dolinger from Bettina Plevan and Jeffrey Burstein dated 10/19/2011 re: Please accept this letter as a joint request of both parties for a two-month extension for completion of fact discovery. ENDORSEMENT: At the parties' request, the deadline to complete fact discovery is extended to January 31, 2012. ( Discovery due by 1/31/2012.) (Signed by Magistrate Judge Michael H. Dolinger on 10/19/2011) (lmb)

11 :54AM

U. S. EMPLOVMEIH OJPORTLlNI"'Y COMM

NO. 1446

P. 2

u.s. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
Newark Area Office
1Nt:Wlli"k ~tc:r, 21" Floor
NewBtk, Nl 07102-5233

Intake lnformation Group: [phone]
Imake Infonnation Group TTY; [phone]
Nowark Status Line: [phone]

Newark Direct Dial: (973) 645-46&4

Jeffrey Burstein
Senior Trial Attorney

Phone: (973) 64S·2267
Fax: [phone]
jeffrey.burstein@ccoc,gov

..

TIY (973) 645-30()4
FAX (973) 64~-4524

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October 19, 2011

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By Fax and by Mail
Hon. 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:

Equal Emplovment OI?J2.ortunity Commission v. Kelley Drye & Warren LLP, 10-CV­
0655 (LTS) (MHD)

Dear Judge Dolinger:
Please accept this letter as ajoint request of both parties tbr a two-month extension for
completion of fact discovery. Presently, pursuant to a ruling by the Court at a June 7, 2(111
hearing~fact discovery is scheduled to end on November 30,2011. While the parties have been
diligently proceeding with discovery, including depositions, problems have arisen in scheduling
depositions for most ofthe high-level Kelley Drye partners EEOC has notified Defendant it
intends to depose due to limitations on such partners' availability for such depositions.
Additional problems in proceeding with such depositions have occurred due to scheduling
conflicts of Defendant's counsel resulting from other litigation, For these reasons, the parties
respectfully request a two-month extension of fact discovery, making January 31,2012 the
termination date for fact discovery, This extension may also necessitate revision ofthe current
schedule for expert discovery, presently set to be completed by January 21, 2012. per Your
Honor's ruling at a July 15,2011 proceeding, However, counsel for the parties are still
discussing this issue, and will present the Court with a written proposal for revised deadlines for
expert discovery, as well as for dispositive motions, no later than Tuesday October 25,2011.
Thank you for Your Honor!s consideration of this matter.

OCT. 19. 2011 11:54AM

U. S. EIVIPLOYMEIH OPPORTUNITY COMM

NO. 1446

Respectfully submitted,

sl Bettina Plevan
Bettina Plevan, Esq.

~
Jeffrey Burstein

I

Attorney for Defendant

Attorney for Plaintiff

Kelley Drye & Waxren LLP

Equal Employment
Opportunity COlllll1ission

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P. 3

FAX Cover Sheet

Date: October 19, 2011
To:
Elizabeth Anne Grossman, Esq.
Fax: [phone]
Jeffrey Charles Burstein, Esq.

Fax: [phone]

Bettina Barasch Plevan, Esq.

Fax: [phone]

Joseph C. O'Keefe, Jr, Esq.

Proskauer Rose LLP

Fax: [phone]

EEOC v. Kelley Drye & Warren, LLP.
10 Civ. 655 (LTS) (MHD)

Re:

Endorsed order: "At the parties' request, the deadline to complete
fact discovery is extended to January 31, 2012."

From:

Magistrate Judge Michael H. Dolinger
United States District Court
Southern District of New York
500 Pearl Street, Room 1670
New York, New York 10007-1312
FAX [phone]
TELEPHONE NUMBER [phone]

This document contains

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pages, including this cover sheet.