Bleiwas v. City Of New York et al

Filing 155

ORDER: granting 154 Letter Motion to Adjourn Conference. The parties' requests for an adjournment of the trial, corresponding extensions of the deadlines for all pre-trial submissions, and an adjournment of the pre-trial conference are GRANTE D. The trial is hereby adjourned to June 21, 2022 at 10 a.m. The pre-trial submissions are hereby due on May 23, 2022, with responses due on June 6, 2022. The pre-trial conference is hereby adjourned to June 16, 2022 at 2 p.m. It is SO ORDERED. Final Pretrial Conference set for 6/16/2022 at 02:00 PM before Judge Edgardo Ramos. Jury Trial set for 6/21/2022 at 10:00 AM before Judge Edgardo Ramos.. (Signed by Judge Edgardo Ramos on 11/22/2021) (ama)

Brett H. Klein, Esq., PLLC
305 Broadway, Suite 600
New York, New York 10007
T: [phone] F: [phone]
November 19, 2021
BY ECF
The Honorable Edgardo Ramos
United States District Judge
40 Foley Square
New York, New York 10007
Re:

Martin Bleiwas v. City of New York, et al., 15 CV 10046 (ER)

Dear Judge Ramos:
I represent the plaintiff in the above-referenced civil rights action. I write with
defendants’ consent to request an adjournment of the trial, which is scheduled to commence
on January 10, 2022, to a date that is convenient to the Court and the parties in the late second
or third quarter of 2022. If the Court were inclined to grant this request, we would request
corresponding extensions of the deadlines for all pre-trial submissions, as well as an
adjournment of the pre-trial conference scheduled for January 6, 2022. The JPTO is currently
due November 22, 2021, and other pre-trial filings are currently due on December 13, 2021.
There are a number of reasons for this request. As an initial matter, the parties are
anxious for this case to reach a conclusion. With the recent appearance of new defense counsel,
the parties have re-opened settlement discussions, and intend to work cooperatively to confirm
if this case can now be settled in lieu of trial. In this regard, the parties may seek the assistance
of the assigned magistrate, but agree that it is premature at this point to ask for a reference.
Further, in addition, an adjournment would help alleviate a crush of trials for the undersigned,
as I have a continued state court trial in mid-December, and I am scheduled to try a jury trial
in the Northern District commencing on January 18, 2022. The requested adjournment will
allow the parties to first focus on a potential resolution while conserving the parties’ and the
Court’s resources. Finally, we ask for late second quarter if not third quarter as I have two
trials scheduled in April 2022.
Thank you for your consideration.
Respectfully,

Brett Klein
cc:

Joshua Lax (by ECF)

The parties' requests for an adjournment of the trial, corresponding
extensions of the deadlines for all pre-trial submissions, and an
adjournment of the pre-trial conference are GRANTED. The trial is
hereby adjourned to June 21, 2022 at 10 a.m. The pre-trial submissions
are hereby due on May 23, 2022, with responses due on June 6, 2022.
The pre-trial conference is hereby adjourned to June 16, 2022 at 2 p.m. It
is SO ORDERED.
11/22/2021