Schoolcraft v. The City Of New York et al

Filing 613

CONSENT LETTER MOTION for Extension of Time to File Reply brief on pending fee application addressed to Judge Robert W. Sweet from Jon L. Norinsberg dated April 18, 2016. Document filed by Adrian Schoolcraft.(Norinsberg, Jon)

JON

L. NORINSBERG
ATTORNEY AT LAW

TRANSPORTATION BUILDING

225 BROADWAY
SUITE 2700
NEW YORK, NEW YoRK

10007

www.norinsberglaw.com
BRONX OFFICE
TEL [phone]
FAX [phone]

5938 FmLDSTON ROAD
BRONX, NEW YORK 10471
JON

E-MAIL: [e-mail]

L. NORINSBERG

JOHN

J. MEEHAN

April 18, 2016
Honorable Robert W. Sweet
United States District Judge
Southern District of New York
500 Pearl Street
New York, New York 10007

Re:

Scl,oolcraft v. The City of New York, et al
Index No.10-cv-6005

Dear Judge Sweet:
On behalf of all of plaintiffs counsel, I am writing now to request that the Court issue an
Order, nunc pro tune, extending plaintiffs time to submit a Reply brief on the pending fee
application, from April 15, 2016 to April 29, 2016. Defense counsel, Alan Scheiner, Esq, consents
to this request, but asks that the Court also adjourn the date for oral argument on the motion, which
is currently set for May 4, 2016, until May 12, 2016, or any date thereafter that is convenient to the
Court. Plaintiff consents to this request.
There are two reasons for this application. First, plaintiffs counsel mistakenly believed that
our Reply brief was due on April 22, 2016, which would be 14 days after the City filed its
opposition brief. However, as defense counsel correctly points out, the actual wording of the Court's
Order states "14 days after the date of the conference," not 14 days after the date the City's brief is
filed. (Docket No. 591). We apologize to the Court for this oversight, as we truly believed that we
had 14 days, or until April 22, 2016, to respond to the City's brief.

In any event, due to the sheer volume of the City's submission, plaintifrs counsel needs
additional time to respond to the many arguments raised by the City and its expert, Judith Bronsther.
The brief itself is 73 pages long. The expert's report is 118 pages long without exhibits, and 295
pages with exhibits. Given the enormous volume of this submission, plaintifrs counsel requires
additional time to respond to the City's opposition papers.
Based on the foreoing, plaintiff respectfully requests that the Court issue an Order, nunc pro
tune, extending plaintifrs time to submit a Reply brief on the fee application from April 15, 2016
to April 29, 2016, and if the Court grants this request, adjourning the date for oral argument on the
fee application from May 4, 2016, until May 12, 2016, or any date thereafter that is convenient to
the Court.
We thank the Court for its consideration of this request.

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