Schoolcraft v. The City Of New York et al

Filing 523

ORDER granting 490 Letter Motion for Leave to File Excess Pages. So ordered. (Signed by Judge Robert W. Sweet on 9/21/2015) (ajs)

Case 1:10-cv-06005-RWS Document 490 Filed 09/18/15

Page 1 of 2

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ZACHARY W. CARTER
Corporation Counsel

THE CITY OF NEW YORK .

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LAW DEPARTMENT
I 00 CHURCH STREET
NEW YORK, NY I 0007

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Honorable Robert W. Sweet
United States District Judge
Southern District of New York
500 Pearl Street
New York, New York 10007

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ALAN· H; SCHEINER
Senior Counsel
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Re: Schoolcraft v. City of New York, et al., 1O-cv-6005 CR WS)
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 a page limit extension for the Memorandum of Law in Support
of City Defendants' Motions In Limine from 25 to 50 pages, and to separately file a motion to
preclude the testimony of four experts, in whole or in part, with a 25 page memorandum.
Plaintiff has listed over 200 exhibits and 56 witnesses, including 4 expert witnesses, in
his JPTO. The medical defendants offer three experts. In contrast, City Defendants do not offer
any expert witnesses. In light of the large number of exhibits and witnesses listed by plaintiff,
the need for expert-related motions, and the complexity of the issues in the case (including
Monell issues), the City Defendants believe that an increase in the Court's usual page limits are
required.
We have conferred with the other parties and although plaintiff agreed to a 50 page limit
for motions in limine, plaintiff has not responded to our request to file a separate motion directed
at the preclusion of expert witness testimony. Given the large number of plaintiff experts,
requiring expert motions to be included within the same page limit as other motions would be
unfair to the City defendants, who will be making motions directed at several expert witnesses.

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Case 1:10-cv-06005-RWS Document 490 Filed 09/18/15 Page 2 of 2
Hon. Robert W. Sweet, U.S.D.J.
September 18, 2015
Page 2 of2
Accordingly, the City Defendants respectfully request a page limit extension for the
Memorandum of Law in Support of City Defendants' Motions In Limine from 25 to 50 pages
and a 25 page limit for a separate Memorandum of Law in Support of City Defendants' Motions
to Preclude Expert Testimony.
We thank the Court for its consideration in this matter.

Respectfully submitted,

Isl Alan Scheiner
Alan Scheiner
Senior Counsel
cc:

All counsel (via ECF)