Schoolcraft v. The City Of New York et al

Filing 488

CONSENT LETTER addressed to Judge Robert W. Sweet from Cheryl L. Shammas dated September 15, 2015 re: Request to Extend Deadline to File Motion in Limine from September 17th to September 21st. Document filed by Christopher Broschart(Tax Id. 915354 in his official capacity), Christopher Broschart(Tax Id. 915354 Individually), Timothy Caughey(Tax Id. 885374 Individually), Timothy Caughey(Tax Id. 885374 in his official capacity), Kurt Duncan(Shield No. 2483, Individually), Kurt Duncan(Shield No. 2483 in his official capacity), William Gough(Tax Id. 919124, Individually), William Gough(Tax Id. 919124, in his Official Capacity), Elise Hanlon(in her official capacity as a lieutenant with the New York City Fire Department), Elise Hanlon(individually), Shantel James(Shield No. 3004 in his official capacity), Shantel James(Shield No. 3004 Individually), Theodore Lauterborn(Tax Id. 897840 in his official capacity), Theodore Lauterborn(Tax Id. 897840, Individually), Michael Marino, Michael Marino, Gerald Nelson(Assistant Chief Patrol Borough Brooklyn North, Tax Id. 912370 in his official capacity), Gerald Nelson(Assistant Chief Patrol Borough Brooklyn North, Tax Id. 912370, Individually), Robert W. O'Hare(Tax Id. 916960, Individually), Robert W. O'Hare(Tax Id. 916960, in his Official Capacity), Frederick Sawyer(Shield No. 2576 in his official capacity), Frederick Sawyer(Shield No. 2576, Individually), The City Of New York.(Shammas, Cheryl)

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ZACHARY W. CARTER Corporation Counsel THE CITY OF NEW YORK LAW DEPARTMENT 100 CHURCH STREET NEW YORK, NY 10007 CHERYL L. SHAMMAS Senior Counsel phone: (212) 356-2406 fax: (212) 356-3509 September 15, 2015 BY ECF & EMAIL ( Honorable Robert W. Sweet United States District Judge Southern District of New York 500 Pearl Street New York, New York 10007 Re: Schoolcraft v. 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 the City Defendants in the above-referenced matter. We write to respectfully request an adjournment of the motion in limine filing deadline from September 17, 2015 to September 21, 2015. The deadline was previously adjourned in connection with adjournments of the deadline for the JPTO, most recently by operation of the Court’s order of September 10, 2015 (Docket No. 487). The reason for this request is that lead counsel for the City defendants, Alan Scheiner, suffered a relapse of a respiratory infection late Thursday last week, resulting in a serious bronchitis with fever. He has been out of the office and unable to work full-time as a result. We hope that he will be able to return to work soon. All parties consent to this request. We thank the Court for its consideration in this matter. Respectfully submitted, /s/Cheryl Shammas Cheryl Shammas Senior Counsel cc: All counsel (via ECF)

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