Schoolcraft v. The City Of New York et al

Filing 444

LETTER MOTION for Extension of Time to File Opposition and Reply briefs for all parties to the Motions for Reconsideration and Motion for Bifurcation Filed on June 2, 2015 addressed to Judge Robert W. Sweet from Alan H. Scheiner dated June 5, 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

June 5, 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. I write
to advise the Court of a briefing schedule agreed to by all the parties for the motions for
reconsideration and motion for bifurcation filed on June 2, 2015. All parties agree to the
following, which is an adjournment of one week of the default briefing schedule in Local Rule
6.1, incorporated by Local Rule 6.3.
Opposition Memoranda Due:

June 23, 2015

Reply Memoranda Due:

July 3, 2015

We respectfully request that the Court So Order this 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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