Ameruso v. City of New York et al

Filing 124

ORDER granting 123 Letter Motion to Adjourn Conference. Application granted. The conference to discuss Defendants' pending motion is adjourned until January 8, 2020 at 3:00 p.m. Status Conference set for 1/8/2020 at 03:00 PM before Judge Ronnie Abrams. (Signed by Judge Ronnie Abrams on 12/5/2019) (rj)

Application granted. The conference to discuss
Defendants' pending motion is adjourned until January 8,
2020 at 3:00 p.m.

SO ORDERED.

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DOCUMENT
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December 5, 2019

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JAMES E. JOHNSON
Corporation Counsel

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BRACHAH GOYKADOSH
Senior Counsel
[e-mail]
Phone [phone]
Fax: [phone]

THE CITY OF NEW YORK

LAW DEPARTMENT
100 CHURCH STREET
NEW YORK, NEW YORK 10007

December 4, 2019

ByECF
Honorable Ronnie Abrams
United States District Court Judge
United States District Court
Southern District ofNew York
Thurgood Marshall Courthouse
40 Foley Square
New York, New York 10007
Re:

Marc Ameruso v. City of New York, et al., 15 Civ. 3381 (RA)

Your Honor:
I am a Senior Counsel in the Office of James E. Johnson, Corporation Counsel of the City of New
York, and the attorney assigned to the defense in the above-referenced matter. In that capacity, I write to
respectfully request an adjournment of the conference currently-scheduled for December 11, 2019 at
3: 15 p.m. (Docket Entry No. 122).
As the Court is aware, on July 13, 2017, defendants moved for summary judgment. (Docket
Entry No. 98). On December 3, 2019, the Court scheduled a conference to discuss defendants' pending
motion. (Docket Entry No. 122). The conference is scheduled for December 11, 2019 at 3: 15 p.m.
Defendants now seek an adjournment of that conference. The reason for this request is that the
undersigned is unavailable at that time, as she will be immersed in trial preparation for a trial scheduled to
commence before the Honorable Kiyo A. Matsumoto in Eastern District of New York on December 16,
2019 in Yaakov Pukhovich v. City of New York, et al., 16-cv-1474. 1 Plaintiffs counsel consents to
defendants' request for an adjournment of the conference, which is the first of its kind. The parties have
conferred and would be available for a conference any time on December 23, 2019.
Thus, defendants respectfully request that the Court adjourn the conference scheduled for
December 11, 2019 to any time on December 23, 2019 or any other time convenient for the Court.
Thank you for your consideration herein.
Respectfully submitted,
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Brachah Goykadosh
Senior Counsel
Special Federal Litigation Division
1

Jury selection in the Pukhovich trial is scheduled for December 9, 2019.