K.A. et al v. City Of New York et al

Filing 162

ORDER granting 161 Letter Motion for Extension of Time to File. The foregoing extension requests are granted. DE 161 is resolved. SO ORDERED. (Signed by Judge Laura Taylor Swain on 8/10/2022) (vfr)

Case 1:16-cv-04936-LTS-JW Document 162
161 Filed 08/11/22
08/09/22 Page 1 of 2

THE CITY OF NEW YORK

LAW DEPARTMENT

HON. SYLVIA O. HINDS-RADIX
Corporation Counsel

100 CHURCH STREET
NEW YORK, NY 10007

MEMO ENDORSED

ALAN H. SCHEINER
Senior Counsel
Tel. [phone]
Fax. [phone]
email: [e-mail]

August 9, 2022

Via ECF
Hon. Laura Taylor Swain
United States District Court
Southern District of New York
500 Pearl Street
New York, New York 10007
Re:

K.A., et al. v. City of New York, et al., 16-cv-04936 (LTS) (KNF) (SDNY)

Your Honor:
I am a Senior Counsel in the Office of Hon. Sylvia O. Hinds-Radix, the Corporation
Counsel of the City of New York, assigned to the defense of the above-referenced action on behalf
of defendant City of New York (the “City”). I am writing to respectfully request an extension of
time for: (1) the City and the Corizon defendants (the “Defendants”) to submit their Reply
memoranda in support of their motions to dismiss, from August 12, 2022 to August 19, 2022; and
(2) the time for the City and the Corizon defendants to submit an appeal under Fed. R. Civ. P. 72
of the Magistrate Judge’s Order of July 28, 2022 (ECF No. 156) denying Defendants’ motion to
stay discovery, in whole or in part, during the pendency of the motions to dismiss, from August
11, 2022 to August 16, 2022. Plaintiffs consent to this request. This is the second request for
extension of the time to Reply, the first request was granted upon consent. This is the first request
for extension of time to submit the Rule 72 appeal.
The extensions are required because of the continuing need for the City’s counsel to attend
to the medical needs of a child who is recovering from a significant surgery that occurred on July
26, 2022. (This is the medical emergency referenced in the prior applications for an extension of
made on August 1, 2022, ECF Nos. 158, 160). As a result of this family medical issue, the City’s
counsel has been unable to fully attend to the Magistrate Judge’s Order of July 28, 2022 or the
preparation of the Reply on the motion to dismiss.

Case 1:16-cv-04936-LTS-JW Document 162
161 Filed 08/11/22
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The Corizon defendants join in this request because judicial economy calls for all
defendants to make their applications together, and the Defendants may wish to incorporate codefendants arguments to avoid duplicative filings.
We thank the Court for its consideration of this matter.
The foregoing extension requests are granted. DE 161 is
resolved.
SO ORDERED.
8/10/2022
/s/ Laura Taylor Swain, Chief USDJ

cc:

All Counsel (via ECF)

-2-

Respectfully submitted,

Alan H. Scheiner /s/

Alan H. Scheiner
Senior Counsel
Special Federal Litigation Division