Alvarado Balderramo et al v. Go New York Tours Inc. et al

Filing 236

ORDER granting in part and denying in part 232 Letter Motion for Discovery. Defendants' request is granted in part. Defendants may depose Plaintiff for 2 additional hours. Appropriate accommodations must be provided to account for translation. The Clerk of Court is respectfully directed to terminate Doc. 232. (Signed by Judge Edgardo Ramos on 4/27/2021) (cf)

LAW OFFICE

OF

JUSTIN A. ZELLER, P.C.
J USTIN A. Z ELLER
JAZELLER @ ZELLERLEGAL . COM

T ELEPHONE : 212.229.2249
F ACSIMILE : 212.229.2246

J OHN M. G URRIERI
JMGURRIERI @ ZELLERLEGAL . COM

VIA ECF

Final page

Hon. Edgardo Ramos United States District Judge
United States District Court for the Southern District of New York
Re: Alvarado Balderramo et al v. Go New York Tours Inc. et al
Dear Judge Ramos:
-reference action.
p
the defendants’ motion to enlarge the day and duration limits on the deposition of

will oppose
.

enlargement of the limits.
the record.
nsel were prepared to
continue for the remaining hour within the limit. No record was
no such contention is made in the defendants’
letter.
“Unless otherwise stipulated
e
See Margel v. E.G.L. Gem Lab Ltd.

fairly depos
eir entitlement to more time.
entitle the interrogating party more time
state that the need for interpreter is one of a
variety of factors the Court may consider. See
–
Republic of Turkey v. Christie’s, Inc. the Court allowed additional time for a
Amendment.
deposition “mindful of the additional time it tak
But the court
also on the need for additional time to
uced
after the initial depositions took place. See id. at
.

277 B ROADWAY , S UITE 408, N EW Y ORK , N.Y. 10007-2036

late production of documents. As to what additional topics
—
s role as a class
it is not
the course of

; it is not
the litigation.

forgotten is the rule’s cross-reference to
which states “
’s claim or defense and proportional to the needs of the case....
same crossJust as the
Court must scrutinize whether
of right we
the Court should not grant a party more time to conduct a
“

Margel
at
Defendants’

Among the

defendants
and who he has declared as
–
–
–
–
– .

–

–

–

defendants

family including his
. See
–
–
Case law is deci
See Rosas v. Alice’s Tea

Cup, LLC
the depone
his wife’s immigration status.
resident. See Dep. Pl.
–
–
defendants
card.
defendants asked for
See e.g.,
– ;
–

asked
–

is a lawful permanent
the

– .

–

– .
his attorneys. See

–

–

– . Defendants
ed “no . See Dep.

–

–

–

–

–
his answer was

“no See

–

–

defendants
employers
–
–
.

–

–

–

Defendants
with
See Alvarado v. Taxi Tours Inc.
–
–
–
–
–

–

–

ons
.
–

–

See
Defendants

work history with other
See Dep. Pl.
–
–
and

See
–

–

–
–

–
–

–

– .

if he
payments from his employer after he
–
d

See

intimidate
for the Court
the Rules’ time limits. But time the defendants spent on patently
the
amount of time defendants wasted asking
and therefore

.
.

deposition—

—

cept

r.

his calcul
–
–
–

–
–
See Dep. Pl.
–

–
–

–
–
;
–

–

–

–
–

. See
–

–

–
–

–
–

–

–

–

–

wing additional time.
referenced are clearly
.
that testimony regarding the accuracy of their records
especially w
case
time spent
regarding this issue in

defendants
.
additional time

deposition time

.

Enclosures

Defendants' request is granted in part. Defendants may depose
Plaintiff for 2 additional hours. Appropriate accommodations
must be provided to account for translation. The Clerk of
Court is respectfully directed to terminate Doc. 232.
SO ORDERED.

4/27/2021