Schoolcraft v. The City Of New York et al

Filing 20

ENDORSED LETTER addressed to Judge Robert W. Sweet from Donna A. Canfield dated 9/1/2010 re: Requesting a sixty day (60) extension of time to answer or otherwise respond to plaintiff's complaint until November 2, 2010. ENDORSEMENT: So Ordered. (Signed by Judge Robert W. Sweet on 9/4/2010) (jpo)

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JUDGE SWEET CHAMBERS

THE CITY OF NEW YORK

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LAW DEPARTMENT

MJCHA Et ."-. CARDOZO

100 CHURCH STREET
NEW YORK, NY 10007

Cmpora/iol! C{)lI.nsr:/

nONNA A. CANFIELD
phone [phone]
fax [phone]
mobile. [phone]

email; dC![e-mail]

September 1, 2010

BY FACSIMILE: 212-805-7925
Honorable Robert W. Sweet
United States District Judge
Southem District of New York
500 Peru:l Street
N ew York, New Yark 10007

Re: Schoolcraft v. The City of Ne,x.: York. et aL

Civil Action NUmber: 10 CV 6005

City Number: 2010-033074

Dear Judge Sweet:
I am the Assistant Corporation Counsel in the office of Michael A Cardozo,
Corporation Counsel of the City of New York, assigned to represent the City of New York and
the New York City Police Department ("NYPD") (collectively the "City defendants") in the
above-referenced matter. I write, with the consent of plaintiffs counsel, to request a sixty~day
(60) extension of time to ans\ver or othern1se respond to plaintiff's Complaint from September
3,2010 to November 2010. The City defendants were served with the Complaint on August
1 2010. Accordingly, the City defendant's response is currently due September 3, 2010.
Plaintiff, a former police officer vvith the NYPD, brings this action pursuant to 42
U.S.C. § 1983 ruld 42 U.S.c. § 1988 for violations of his First, Fourth, and Fourteenth
Amendments, and under New York State tort law against the City defendants, ten (10)
individually-named members of the NYPD, Jamaica Hospital, and two (2) individually named
Jamaica Hospital defendants. The City defendants are requesting this extension on behalf of The
City of New York, the NYPD, and the individually-named members of the N'Y'PD in order to
afford this office the opportunity to properly investigate the allegations contained in the
Complaint, detennine the scope of our representation, and prepare an appropriate response.
This is the City defendant's first request for an extension of time.

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Honorable Robert W. Sweet

SchQQlcraft v. The City ofNew York, et al.

S,,-/ccl11ber 1,2010

Page 2
F or these reasons, the City defendants respectfully request an extension of time to
ans\vcr or otherwise respond to plaintiff's Complair~t 'Until November 2, 2010.
I thank the Court for its consideration of this request,

Donna A. Canfield
Assistant Corporation Counsel
[e-mail]
cc:

Jon L. Norinsberg
Attorney for Plaintiff
225 Broadway, Suite 2700

New York, New York 10007

(By Ernail: [e-mail])

Cohen & Fitch, LLP

Gerald Cohen

Joshua Fitch

Attorneys for Plaintiff
Broadway, Suite 2700

New York, New York 10007

(By Email: [e-mail];[e-mail])

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