Ewers v. City Of New York et al

Filing 123

ORDER: granting 122 Letter Motion for Extension of Time to File. Application granted. Defendants' motion for summary judgment is due September 9, 2020; plaintiff's opposition is due October 9, 2020; defendants' reply is due October 26, 2020. (Signed by Judge Naomi Reice Buchwald on 9/01/2020) (ama)

Case 1:17-cv-01116-NRB Document 122 Filed 09/01/20 Page 1 of 2
123

THE CITY OF NEW YORK

LAW DEPARTMENT

JAMES E. JOHNSON
Corporation Counsel

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

100 CHURCH STREET
NEW YORK, NY 10007

September 1, 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

Defendants' motion for
Application granted.
summary judgment is due September 9, 2020;
plaintiff's opposition is due October 9, 2020;
defendants' reply is due October 26, 2020.

Dated: September 1, 2020

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 brief one week extension of
time, from September 2 to September 9, 2020, to file defendants’ motion for summary judgment
due to a family emergency. This is the second request for an extension of this deadline. Plaintiff
pro se did not respond to counsel’s attempt to gain his position on this request. However given
the urgency of this request, plaintiff may not have had an opportunity to respond to the
undersigned’s email requesting his position.
As the Court is aware, defendants previously requested an extension of this deadline,
which Your Honor granted on July 27. See Docket Nos. 120-121. As Your Honor noted that it
would be the final extension of this motion, I have been working on defendants’ motion and was
set to file it tomorrow as scheduled. However, a family medical emergency arose this weekend
that has required much of my time and attention the last few days. While I have done my best to
continue working on the motion, I have been unable to finalize the motion given the family
emergency that arose.

Case 1:17-cv-01116-NRB Document 122 Filed 09/01/20 Page 2 of 2
123

Accordingly, I am respectfully requesting a brief one week extension of time to finalize
and file defendants’ motion. I sincerely apologize to the Court and plaintiff for this unforeseen
delay.
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

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