Forte v. McNellis et al

Filing 170

ORDER granting 169 Letter Motion for Extension of Time to Complete Discovery; granting 169 Letter Motion to Adjourn Conference. APPLICATION GRANTED. The post-discovery status conference scheduled for September 18, 2020 is adjourned to November 19, 2020 at 11:00 am. ( Status Conference set for 11/19/2020 at 11:00 AM before Judge Vernon S. Broderick.) (Signed by Judge Vernon S. Broderick on 7/29/2020) (mro)

Case 1:16-cv-00560-VSB Document 169 Filed 07/28/20 Page 1 of 1
170
07/29/20

Reed Smith LLP
599 Lexington Avenue
New York, NY 10022-7650
[phone]
Fax [phone]
reedsmith.com

Jonathan P. Gordon
Direct Phone: [phone]
Email: [e-mail]

July 28, 2020
VIA ECF
7/29/2020

Honorable Judge Vernon S. Broderick
United States District Court Judge
40 Foley Square, Room 415
New York, NY 10007
Re:

The post-discovery status conference scheduled for
September 18, 2020 is adjourned to November 19, 2020
at 11:00 am.

Forte v. McNellis et al., Case No. 1:16-cv-00560-VSB (S.D.N.Y)

Dear Judge Broderick:
We represent Plaintiff Daniel Forte as limited pro bono counsel in the above-referenced matter
pursuant to Your Honor’s Order dated November 30, 2018. (ECF No. 124) Pursuant to Rule I.G. of Your
Honor’s Individual Rules & Practice in Civil Cases, we write on behalf of all parties to respectfully request
an extension of the deadline to complete fact discovery from September 1, 2020, to November 1, 2020,
and an adjournment of the status conference scheduled for September 18, 2020.
The parties previously requested and Your Honor granted extensions of the deadline to complete
fact discovery in February, March, and April 2020. (See ECF Nos. 156, 163, 165) The previous two
requests for extension were made in light of safety concerns and travel and workplace restrictions arising
from the COVID-19 pandemic. The parties had hoped that the most recent extension would provide
sufficient time for the widespread workplace and travel restrictions to subside, enabling the depositions
of the defendant officers, which is the last component of discovery that remains outstanding, to be
completed in-person. Recognizing that it is a best uncertain as to when conditions will permit in-person
examinations, the parties have agreed to complete the outstanding depositions by videoconference.
In order to provide time for coordination among all parties and all deponents, one of whom is
retired and resides out-of-state, to appear via videoconference, the parties respectfully request a further
extension of the deadline to complete fact discovery to November 1, 2020 and an adjournment of the status
conference scheduled for September 18, 2020 to a convenient date and time in November 2020.
We thank the Court for its attention to this matter.
Respectfully submitted,
/s/ Jonathan P. Gordon
Jonathan P. Gordon
cc:

By ECF
Counsel of Record
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