Range, Jr. v. 230 West 41st Street LLC et al

Filing 101

ORDER granting 100 Letter Motion for Extension of Time to File. SO ORDERED. (Signed by Judge Loretta A. Preska on 4/7/2020) (va)

Case 1:17-cv-00149-LAP Document 100 Filed 04/06/20 Page 1 of 2
Seyfarth Shaw LLP
620 Eighth Avenue
New York, New York 10018
T [phone]

SO ORDERED.
Dated: April 7, 2020
New York, NY

F [phone]
[e-mail]
T [phone]
www.seyfarth.com

April 6, 2020
VIA ECF

___________________________
LORETTA A. PRESKA, U.S.D.J.

Hon. Loretta A. Preska
United States District Judge
United States District Court for the Southern District of New York
500 Pearl Street
New York, NY 10007
Re:

Range, Jr. v. 230 West 41st Street LLC et al.,
Civil Action No.: 1:17-cv-00149-LAP

Dear Judge Preska:
This firm represents Defendant 230 West 41st Street LLC (“230 West”) in the
above referenced matter. We write, jointly with Defendant Hat Trick Pizza, Inc.
(collectively with 230 West, “Defendants”), and with the consent of Plaintiff King Range,
Jr. (“Plaintiff”), Domino’s Pizza LLC, and Domino’s Pizza Franchising LLC, to respectfully
request a one week extension of Defendants’ deadline to submit their reply papers in
support of summary judgment, from April 9, 2020 to April 16, 2020.
By way of background, Defendants filed their motion for summary judgment on
February 7, 2020. (ECF Nos. 80-89.) On March 5, 2020, Plaintiff requested an additional
week to file his opposition papers, which the Court granted. (ECF Nos. 93, 95.) Plaintiff
filed his opposition papers on March 12, 2020. (ECF Nos. 96-99.)
Defendants’ reply is presently due on April 9, 2020. Defendants respectfully
request the additional time in order to complete briefing on this motion, given the
substantial business disruption and related challenges presented by the current public
health emergency. Defendants are endeavoring to complete the briefing on the motion
as soon as practicable, and this application is accordingly not intended to cause undue
delay.
The undersigned has communicated with counsel for Plaintiff, Domino’s Pizza LLC
and Domino’s Pizza Franchising LLC, and these parties consent to this request. This is
Defendants’ first request for an extension of this deadline (although the deadline was
previously adjusted based on Plaintiff’s previous application for an extension of briefing),
which, if granted, will not impact any other deadlines. We thank the Court for its time and
attention to this matter, and for its consideration of this application.

Case 1:17-cv-00149-LAP Document 100 Filed 04/06/20 Page 2 of 2
Hon. Loretta A. Preska
April 6, 2020
Page 2
Respectfully submitted,
SEYFARTH SHAW LLP
/s/ John W. Egan
John W. Egan
cc:

All counsel of record (via ECF)