Ruiz v. Keratin Bar

Filing 123

ORDER: granting 122 Letter Motion for Extension of Time to File. Application GRANTED. Trial is adjourned to March 31, 2020, at 10:00 a.m. The FPTC is adjourned to March 23, 2020, at 2:00 p.m. The Parties' JPTO is due no later than February 25, 2020. SO ORDERED. (Signed by Judge Valerie E. Caproni on 2/06/2020) (ama)

Case 1:17-cv-02216-VEC Document 122 Filed 02/06/20 Page 1 of 2

MEMO ENDORSED
February 6, 2020
Via ECF
The Honorable Valerie E. Caproni
United States District Judge for the
Southern District of New York
40 Foley Square
New York, New York 10007
Re:

USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 2/6/2020

Ruiz v. Keratinbar Inc., et al; Case No. 17-cv-02216 (VEC)

Dear Judge Caproni:
This firm represents Plaintiff Angel Ruiz in the above-referenced employment
discrimination matter against Defendants Keratinbar Inc. and 1976 Haircare Inc. We write to
respectfully request, with Defendants’ consent, one final extension of time for the parties to file
their Joint Pre-Trial Order (“JPTO”), which is currently due on Monday, February 10, 2020, until
Friday, February 21, 2020..
We are requesting an extension to file the JPTO so that the parties can focus their efforts
on reaching an amicable resolution. With the assistance of Rebecca Price, Esq., the mediator
assigned to this case, the parties continue, in earnest, to make significant progress in bridging the
gap between their respective demands and offers. In fact, at least one of the parties has spoken
with Ms. Price on each business day since January 30, 2020, the date the parties submitted their
second joint request for an extension to file the JPTO. In addition, while the parties are currently
collaborating on the JPTO in preparation for trial, in order to avoid the significant time and costs
that the parties will expend to further prepare for and conduct a trial, and to preserve judicial
resources, the parties respectfully request additional time to complete the JPTO so that they can
continue to engage in hopefully fruitful settlement negotiations.

Case 1:17-cv-02216-VEC Document 122 Filed 02/06/20 Page 2 of 2

There is a pre-trial conference scheduled for Monday, February 24, 2020. Hopefully
granting this extension will not deprive the Court of enough time to review the pre-trial
submissions before that conference, but if it would, the parties respectfully request a brief
adjournment of the conference to later in the same week, such as February 27 or 28, subject of
course to the Court’s availability.
We thank the Court for its time and attention to this matter.

Respectfully submitted,

___________________
William K. Oates, Esq.
For the Firm
C:

All Parties (via ECF)

Application GRANTED. Trial is adjourned to March 31, 2020, at 10:00
a.m. The FPTC is adjourned to March 23, 2020, at 2:00 p.m. The Parties'
JPTO is due no later than February 25, 2020.
SO ORDERED.

2/6/2020
HON. VALERIE CAPRONI
UNITED STATES DISTRICT JUDGE

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