Ewers v. City Of New York et al

Filing 121

ORDER: granting 120 Letter Motion for Extension of Time to File. Application granted. Final extension. Defendants' motion for summary judgment is due September 2, 2020; plaintiff's opposition is due October 2, 2020; defendants' reply is due October 19, 2020. (Signed by Judge Naomi Reice Buchwald on 7/29/2020) (ama)

Case 1:17-cv-01116-NRB Document 120 Filed 07/27/20 Page 1 of 2
121
07/29/20

THE CITY OF NEW YORK

LAW DEPARTMENT

JAMES E. JOHNSON
Corporation Counsel

100 CHURCH STREET
NEW YORK, NY 10007

ERIN T. RYAN
Assistant Corporation Counsel
Phone: [phone]
[e-mail]

July 27, 2020

VIA ECF
Hon. Naomi Reice Buchwald
United States District Judge
United States District Court
Southern District of New York
500 Pearl Street
New York, New York 10007
Re: Ewers v. City of New York, et al., 17-CV-1116 (NRB)
Your Honor:
I am an Assistant Corporation Counsel in the Office of Zachary W. Carter, Corporation
Counsel of the City of New York, and the attorney assigned to represent defendants in the above
referenced matter. In that capacity, I write to respectfully request a thirty (30) day extension of
time, from August 3 to September 3, 2020, to file defendants’ motion for summary judgment.
This is the first request for an extension of this deadline. Plaintiff pro se did not respond to
counsel’s attempt to gain his position on this request.
At the Court’s request, defendants filed a pre-motion conference letter on June 10,
2020, outlining defendants’ anticipated motion for summary judgment. See Docket No. 118.
The Court granted defendants permission to file their motion, and set the following briefing
schedule: motion due August 3; opposition due September 2; reply due September 17. See
Docket No. 119.
There are two reasons for this extension request. First, I will be out of the office the
week of July 27, the week before the motion is due, and need additional time to finalize
defendants’ motion. Second, I am currently in motion practice in two other cases, and my replies
in those matters are due August 14 and August 20, respectfully. 1 Accordingly, I respectfully
1

I am currently in motion practice in the matters of Hoa Lay v. Sea Gate Association, et al., 19CV-3076 (EFK) (RML), currently pending in the Eastern District of New York, and Ramon
Guity v. City of New York, et al., 18-CV-10234 (PGG) (SDA), pending in the Southern District
of New York.

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07/29/20

request the thirty day extension to file defendants’ motion in this case to ensure I have sufficient
time to complete all motions.
Thank you for your consideration of the herein.
Respectfully submitted,
/s/
Erin Teresa Ryan
Assistant Corporation Counsel
Special Federal Litigation Division
cc:

By ECF and E-Mail
Altura St. Michael Ewers, Plaintiff Pro Se
Application granted. Final extension.
Defendants' motion for summary judgment is
due September 2, 2020; plaintiff's opposition
is due October 2, 2020; defendants' reply is
due October 19, 2020.

Dated: July 29, 2020

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