Schoolcraft v. The City Of New York et al

Filing 563

LETTER MOTION for Extension of Time to February 29, 2016 to Respond to Motion for Fees and Expenses addressed to Judge Robert W. Sweet from Alan H Scheiner dated December 18, 2015. Document filed by The City Of New York.(Scheiner, Alan)

ZACHARY W. CARTER
Corporation Counsel

THE CITY OF NEW YORK

LAW DEPARTMENT
100 CHURCH STREET
NEW YORK, NY 10007

ALAN H. SCHEINER
Senior Counsel
phone: [phone]
fax: [phone]
[e-mail]

December 18, 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. Jamaica Hospital Medical Center, 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, representing the motion respondent City of New York (the “City”), in
connection with the trial of above-captioned matter.
The City writes to respectfully request a two-month extension of the time for the City to
respond to the plaintiff’s motion for attorneys’-fees and costs, made pursuant to the judgment
pursuant to Rule 68 entered against the City on October 16. 2015, from December 30, 2015 to
February 29, 2015. This is the first request for adjournment of this deadline and plaintiff’s
counsel consents to this request.
The two-month adjournment is requested because the time is required to analyze and
respond to the plaintiff’s voluminous submission, which was filed two months after entry of
judgment on October 16, 2015, and encompasses fees and costs claimed by at least 13 different
counsel and paralegals over a five year period. The Memorandum of Law in support of the
motion is 40 pages long, and 31 exhibits (including 18 declarations, many from persons not
appearing in this matter), were filed in support of the motion. In addition, the City had no prior
knowledge of the fee and cost information submitted by plaintiff nor even the amount that would
be claimed. Counsel have agreed to confer, after the City has had an opportunity to review the
submission, during the period of the adjournment, in an attempt to resolve the motion.

Sweet, J.
October 28, 2015
Page 2

We thank the Court for its consideration in this matter.
Respectfully submitted,
/s/
Alan H. Scheiner
Senior Counsel
Special Federal Litigation Division
cc:

All counsel by ECF