Dolcine v. Hanson et al

Filing 75

ORDER: granting in part 74 Letter Motion for Extension of Time to Complete Discovery; granting in part 74 Letter Motion to Adjourn Conference. Application GRANTED in part. The deadline to complete fact discovery is EXTENDED to December 31, 2019. The conference scheduled for December 13, 2019, is ADJOURNED to January 3, 2020, at 10:00 a.m. The parties' joint preconference letter is due December 30, 2019. The Court will not grant further extensions absent extraordinary circumstances. SO ORDERED.( Pretrial Conference set for 1/3/2020 at 10:00 AM before Judge Valerie E. Caproni.) (Signed by Judge Valerie E. Caproni on 12/04/2019) (ama)

MEMO ENDORSED

USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 12/5/2019

December 3, 2019
BY ECF
Honorable Valerie E. Caproni
United States District Judge
Southern District of New York
40 Foley Square
New York, New York 10007
Re:

Dolcine v. Hanson, et al., 17 CV 4835 (VEC) (JLC)

eeplaw.com
80 Pine Street, 38th Floor
New York, New York 10005
T. 212.532.1116 F. 212.532.1176
New Jersey Office
576 Main Street, Suite C
Chatham, New Jersey 07928
JOHN ELEFTERAKIS*
NICHOLAS ELEFTERAKIS
RAYMOND PANEK
OLIVER R. TOBIAS
JEFFREY B. BROMFELD
FAIZAN GHAZNAVI
GABRIEL P. HARVIS
BAREE N. FETT
STEPHEN KAHN
EVAN M. LA PENNA
KRISTEN PERRY – CONIGLIARO
AIKA DANAYEVA
ARIANA ELEFTERAKIS
MICHAEL INDELICATO
MICHAEL MARRON
DOMINICK MINGIONE
JOSEPH PERRY
MARIE LOUISE PRIOLO *
KEYONTE SUTHERLAND
DANIEL SOLINSKY
ANDREW VILLA
*Also Admitted In New Jersey

Your Honor:
I represent plaintiff in the above-referenced action. I write, along with
defendants, to respectfully request an extension of the discovery deadline from
December 12, 2019 to February 3, 2020, along with a corresponding adjournment of
the Pretrial Conference on December 13, 2019, to a date and time convenient to the
Court after the close of discovery. This is the party’s second request for an extension
of the discovery deadline.
To date, hundreds of pages of documents along with audio material have been
exchanged, and plaintiff’s deposition was conducted. The deposition of defendant
Ruffin is scheduled for December 4, 2019, and the parties are working cooperatively to
schedule the remaining depositions of defendants Hanson and Donahue.
Unfortunately, given counsels’ trial schedules1 along with the approaching holidays, the
parties respectfully submit that a brief extension is needed to complete discovery.

1

Counsel for defendants, Ms. Millar, was on trial from November 18 through 21, 2019,
and engaged in preparation the week prior to trial; and Mr. Shaffer will be commencing
a trial on December 9, 2019, which is expected to last approximately six days. The
undersigned was also preparing for a trial in the wrongful conviction matter, Hamilton
v. City of New York, 15 CV 4574 (CBA) (SJB), pending in the Eastern District of New
York. The Hamilton trial was scheduled to commence on November 12, 2019, and

Accordingly, the parties respectfully request an extension of the discovery
deadline until February 3, 2020, along with a corresponding adjournment of the Pretrial
Conference. Thank you for your consideration of this request.
Respectfully submitted,
Baree N. Fett
cc:

All Counsel

Application GRANTED in part. The deadline to complete fact discovery is
EXTENDED to December 31, 2019. The conference scheduled for
December 13, 2019, is ADJOURNED to January 3, 2020, at 10:00 a.m.
The parties' joint preconference letter is due December 30, 2019. The
Court will not grant further extensions absent extraordinary circumstances.
SO ORDERED.

12/4/2019
HON. VALERIE CAPRONI
UNITED STATES DISTRICT JUDGE

counsel for plaintiff had been preparing for the trial - which was expected to continue
for approximately three weeks – during September and October.