Schoolcraft v. The City Of New York et al

Filing 455

LETTER MOTION for Extension of Time to File Reply Briefs on Motions for Reconsideration addressed to Judge Robert W. Sweet from Alan H. Scheiner dated July 16, 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), 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)

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ZACHARY W. CARTER Corporation Counsel THE CITY OF NEW YORK ALAN H. SCHEINER Senior Counsel phone: (212) 356-2344 fax: (212) 788-9776 ascheine@law.nyc.gov LAW DEPARTMENT 100 CHURCH STREET NEW YORK, NY 10007 July 15, 2015 BY ECF & EMAIL (Andrei_Vrabie@nysd.uscourts.gov) 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 respectfully request an adjournment of the date for all parties to submit Reply memoranda of law on the pending motions for reconsideration. All parties have agreed that the Reply date be adjourned from July 17, 2015 to July 23, 2015. This is the second request for adjournment of this date; the prior request was granted. We respectfully request that the Court So Order this amendment to the briefing 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 2

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