Dunham v. City of New York et al

Filing 143

ORDER granting 142 Letter Motion for Extension of Time to File. SO ORDERED. (Signed by Judge Andrew L. Carter, Jr on 3/20/2020) (kv)

3/20/2020

THE CITY OF NEW YORK

LAW DEPARTMENT

JAMES E. JOHNSON
Corporation Counsel

100 CHURCH STREET
NEW YORK, NY 10007

JOSEPH ZANGRILLI
Senior Counsel
Phone: [phone]
Fax: [phone]
[e-mail]

March 19, 2020
BY ECF
Honorable Andrew L. Carter, Jr.
United States District Judge
United States District Court
Southern District of New York
40 Foley Square
New York, New York 10007
Re: Jermaine Dunham v. City of New York,
11 Civ. 1223 (ALC) (SLC)
Your Honor:
I am a Senior Counsel in the office of James E. Johnson, Corporation Counsel of the City
of New York, representing defendants in the above-referenced matter. I write to respectfully
request a two-week extension of time from March 20, 2020 until April 3, 2020, in which to file
defendants’ motion for summary judgment. Plaintiff’s counsel, Jason E. Kornmehl, Esq., consents
to this request. This is defendants’ second request for an extension of time to file their motion for
summary judgment.
Due to the ongoing health crisis, the Corporation Counsel has encouraged all employees
to work from home. As a result, I have been unable to complete certain tasks related to motion
that require my personal presence, including the assembling of exhibits. In addition, as my
Office adjusts to these new and constantly changing circumstances, I have encountered several
technical issues related to remote access that have prevented access to key documents and files.
It is my hope to visit my office during off hours in order to obtain the necessary documents
required to complete the motion and believe a two-week extension of time will allow me to do so
in a safe and responsible manner. Defendants are also requesting a corresponding extension of
time for the filing of opposition and reply papers to May 1, 2020 for opposition and May 15,
2020 for reply.

Defendants thank Your Honor for your consideration herein and apologize for the late
hour of this request.
Respectfully submitted,
/s/
Joseph Zangrilli
Senior Counsel
Special Federal Litigation Division

CC:

Maxwell W. Brown, Esq. (Via ECF)
Jason E. Kornmehl, Esq. (Via ECF)

March 20, 2020