Capitol Records, LLC v. Redigi Inc.

Filing 235

LETTER MOTION for Extension of Time to File Response/Reply to Plaintiffs' June 23, 2016 Pre Motion Conference Letter addressed to Judge Richard J. Sullivan from Sarah M. Matz dated June 28, 2016. Document filed by Redigi Inc..(Matz, Sarah)

Sarah M. Matz
Partner
[e-mail]
Dir: [phone]

June 28, 2016
VIA ECF AND ELECTRONIC MAIL
Hon. Richard J. Sullivan
Thurgood Marshall
United States Courthouse
40 Foley Square
New York, NY 10007-1312
Re:

Capitol Records LLC v. ReDigi Inc., et al. (12 Civ. 00095) (RJS)

Hon. Judge Sullivan:
As you are aware, my firm Adelman Matz P.C., is currently counsel of record for
Defendant ReDigi Inc. (“ReDigi”) in the above-referenced action. Although our firm has been
discharged without cause, as our motion to withdraw as counsel, which was filed yesterday June
27, 2016, is currently still pending before the Court, we have agreed to submit the instant request
for ReDigi.
Pursuant to 1.D of Your Honor’s Individual Practices, ReDigi is respectfully requesting an
extension of its deadline to respond to Plaintiffs’ June 23, 2016 pre-motion conference letter in
anticipation of filing a motion to register the final judgment in other districts [DE 231]. Pursuant
to 2.A of Your Honor’s Individual Practices, the deadline to respond to the Plaintiffs’ June 23,
2016 letter is today. ReDigi is respectfully requesting that its deadline to respond to Plaintiffs’
pre-motion conference letter be extended ten (10) days i.e. up to and including July 8, 2016.
The reason for the request is that ReDigi seeks to consult other counsel to determine how
best to respond to Capitol’s pending request.
There have been no previous requests to extend the deadline to respond to Plaintiffs’ June
23, 2016 pre-motion conference letter. This request does not impact any other deadlines in this
case.
We have conferred with counsel for Plaintiffs concerning this request and they have
advised that Plaintiffs do not consent to this request for an extension. Plaintiffs’ counsel has stated

Adelman Matz P.C.
Phone: [phone] • Fax: [phone]

Mailing:
1173A Second Avenue, Suite 153
New York, New York 10065

Office:
780 Third Avenue, 14th Floor
New York, New York 10017

June 28, 2016
Page 2 of 2

that their reason for refusal is that their client is concerned about the impact of further delays on
its ability to enforce the judgment given the apparent financial condition of ReDigi.
We apologize to the Court in advance for making this request today, rather than forty eight
hours (48) in advance. To preserve the confidentiality of our communications with ReDigi’s new
counsel we cannot explain at length the reasons for not making this request further in advance.
We greatly appreciate Your Honor’s time and consideration in this matter, and should the
Court need any further information we are available at the Court’s convenience.
Respectfully Submitted,
ADELMAN MATZ P.C.

Sarah M. Matz, Esq.

Cc:

Via ECF and Simultaneous E-Mail
Counsel of Record
Via Simultaneous E-mail
ReDigi Inc. (John Ossenmacher [e-mail]; Larry Rudolph [e-mail])