Schoolcraft v. The City Of New York et al

Filing 437

LETTER MOTION for Extension of Time to File JPTO Changing Date from August 12, 2015 to July 27, 2015 and setting the motion in limine brieifing schedule addressed to Judge Robert W. Sweet from Alan H. Scheiner dated May 18, 2015. Document filed by Christopher Broschart(Tax Id. 915354 in his official capacity), Timothy Caughey(Tax Id. 885374 Individually), Kurt Duncan(Shield No. 2483, Individually), William Gough(Tax Id. 919124, Individually), Elise Hanlon(in her official capacity as a lieutenant with the New York City Fire Department), Shantel James(Shield No. 3004 in his official capacity), Theodore Lauterborn(Tax Id. 897840 in his official capacity), Michael Marino, Gerald Nelson(Assistant Chief Patrol Borough Brooklyn North, Tax Id. 912370 in his official capacity), Frederick Sawyer(Shield No. 2576 in his official capacity), The City Of New York.(Scheiner, Alan)

ZACHARY W. CARTER
Corporation Counsel

THE CITY OF NEW YORK

ALAN H. SCHEINER
Senior Counsel
phone: [phone]
fax: [phone]
[e-mail]

LAW DEPARTMENT
100 CHURCH STREET
NEW YORK, NY 10007

May 18, 2015
BY ECF & EMAIL
([e-mail])
Honorable Robert W. Sweet
United States District Judge
Southern District of New York
500 Pearl Street
New York, New York 10007
Re: Schoolcraft v. The City of New York, et al.
10-CV-6005 (RWS)
Your Honor:
I am a Senior Counsel in the office of Zachary W. Carter, Corporation Counsel of the
City of New York, assigned to represent City Defendants in the above-referenced matter.
At the conference before the Court on May 12, 2015, the Court asked the parties to work
out a briefing schedule for motions in limine by which such motions would be fully submitted by
September 10, 2015. The parties have agreed on a briefing schedule, and also have agreed to an
adjustment to the deadlines relating to the JPTO, in order to accelerate submission of the JPTO.
The agreed-upon schedule is as follows:
Parties Exchange JPTO Drafts:

July 13, 2015

JPTO Submitted to Court:

July 27, 2015

Initial Briefs on Motions in Limine Filed: August 17, 2015
Opposition Briefs Filed/Return Date:

September 10, 2015 (no Reply)

Other dates set by the Court on May 12, 2015 are not affected. We respectfully request
that the Court so-order the agreed schedule.

The City defendants thank the Court for its time and attention to these matters.
Respectfully submitted,
/s/
Alan H. Scheiner
Senior Counsel
Special Federal Litigation Division
cc (by email and ECF):
Nathaniel Smith
Jon Norinsberg
John Lenoir
Gerald Cohen
COHEN & FITCH LLP
Attorneys for Plaintiff
Gregory John Radomisli
MARTIN CLEARWATER & BELL LLP
Attorneys for Jamaica Hospital Medical Center
Brian Lee
IVONE, DEVINE & JENSEN, LLP
Attorneys for Dr. Isak Isakov
Matthew Koster
CALLAN, KOSTER, BRADY & BRENNAN, LLP
Attorneys for Lillian Aldana-Bernier
Walter A. Kretz, Jr.
SCOPPETTA SEIFF KRETZ & ABERCROMBIE
Attorney for Defendant Mauriello

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