H. Daya International Co., Ltd. v. DO Denim, LLC et al

Filing 264

ORDER: granting 262 Letter Motion for Extension of Time to File ; granting 263 Letter Motion for Extension of Time to File. Request Granted. The parties shall file all pretrial materials required by the Court's rules by February 6, 2023. SO ORDERED. (Signed by Judge Victor Marrero on 1/26/2023) (ama)

Case 1:16-cv-08668-VM-VF Document 264 Filed 01/26/23 Page 1 of 1
The parties shall file all
pretrial materials required by the Court's
rules by February 6, 2023.
01/26/2023

Dennis Grossman
Attorney At Law
10 Bond Street (#600)
Great Neck, New York 11021
[phone]

Honorable Victor Marrero
United States District Court
500 Pearl Street
New York, New York 10007

01/26/2023

January 25, 2023

CORRECTED LETTER MOTION (CORRECTS ECF 262) 1
Re:

H. Daya International Co., Ltd. v. Do Denim LLC et al. (case no. 16-CV-8668-VM)

Dear Judge Marrero:
My office and Barry Skidelsky, Esq., represent plaintiff H.Daya International Co, Ltd.,
in this action. I write with the consent of all defendants’ counsel for a short one-week extension of
time from Jan. 30, 2023 to Feb. 6, 2023 for the parties file their joint pretrial order, trial briefs, joint
proposed voir dire, proposed requests to charge, and list of witnesses with matters they will address.
Within this short extended time frame, to ensure compliance with the proposed extended
deadline, the parties have agreed to (1) exchange drafts of their trial witness and exhibit lists, joint
jury instructions, and joint jury voir dires by Jan. 31, 2023 at 5:00PM, and for (2) Plaintiff to
provide its comments to Defendants regarding Defendants’ proposed stipulation of facts and
proposed jury voir dire (which were already provided to Plaintiff) by tomorrow, Jan. 26, 2023. The
parties then will work diligently to resolve matters in a timely fashion through the usual back-andforth communications among counsel.
The parties have been working diligently on these matters and respectfully submit that this
short extension of time will enable the parties to complete the pre-trial requirements under Your
Honor’s rules more effectively without impairing trial preparation by the Court or the parties
themselves. There has been no prior request for an extension of this deadline. This requested
extension of time will not require the change of any other Court date or deadline and will not
prejudice any party, as all counsel have consented.
For the above reasons, the parties respectfully request that this Court grant this agreed
motion and extend the deadline from Jan. 30, 2023 to Feb. 6, 2023 for the parties to file their joint
pretrial order, trial briefs, joint proposed voir dire, proposed requests to charge, and list of witnesses
with matters they will address.
Respectfully,

Dennis Grossman
a

cc: All counsel (by ECF)
1

Dennis Grossman

Within the hour, the earlier version of this letter motion (ECF 262) resulted from an inadvertent
misreading of defense counsel’s redline adjustments of plaintiff’s draft.