Schoolcraft v. The City Of New York et al

Filing 49

ENDORSED LETTER: addressed to Judge Robert W. Sweet from Jon L. Norinsberg dated 11/8/2010 re: Counsel for plaintiff requests an extension of the deadline to respond to defendant Jamaica Hospital's motion to dismiss, which is currently scheduled for November 19, 2010, until December 17, 2010. Based on the foregoing, plaintiff respectfully requests that Your Honor grant additional time to respond to defendant's motion to dismiss, and adopt the following briefing schedule: Plaintiff's Opposition: 12/17/2010. Defendant's Reply: 1/21/2011. Oral Argument: 1/26/2011. ENDORSEMENT: So Ordered. (Signed by Judge Robert W. Sweet on 11/8/2010) (js)

NOV-08-2010

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JON

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L. NORINSBERG
A'rrORNEY AT LAW

BRONX OFFICE

TaL [phone]

5626 POST ROAD

[phone]

BRONX, NEW YORI<. 10471

FAX (2 I. 2) 406-6890
E-MAIL: [e-mail]

TEL [phone]
FAX [phone]

BY FACSIMILE
212-805-7925
Honorable Robert W. Sweet
United States District Judge
Southern District of New York
500 Pearl Street
New York, New York 10007
Re:

ScllOo/cra{t v. City of New York! et Ill.

10 CV 6005 (RWS)

Your Honor:

I represent the plaintiff in the above-referenced matter and write to Your Honor to
respectfully request an extension of the deadline to respond to defendant, Jamaica Hospital's
motion to dismiss, which is currently scheduled for November 19, 2010, until December 17,
2010. This is plaintiff's second request for an adjollrnment. Counsel for defendant, Gregory J.
Radomisli, consents to this request.
Since the time of the first request on October 18, 2010, plaintiff's counsel has had to
conduct several out ()f state depositions in the matter of Rodriguez, et al. v. It's Just Lunch
International et aL 07 CV 9227, which is pending before the Honorable Sidney Stein.
Additionally on November 19, 2010 plaintiff's counsel will be starting a wrongful death trial
which will take several weeks to complete. As such, it will be extremely difficult to meet the
currellt response deadline and thus has occasioned the instant request.
Based on the foregoing, plaintiff respectfully requests that Your Honor grant additional
time to respond to defendant's motion to dismiss, and adopt the following briefing schedule:

Plaintiff's Opposition:
Defendant's Reply:
Oral Argument:

December 17,2010
January 21, 2011
January 26, 201 J

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V cry truly yours,

cc:

Gregory J. Radomisli
[phone]

TOTAL P.03