99 Wall Development Inc. v. Allied World Specialty Insurance Company

Filing 271

ORDER granting 270 Letter Motion for Extension of Time to File. Application granted. The parties shall submit a joint letter by no later than August 3, 2022 proposing potential dates for trial and estimating its length. SO ORDERED.. (Signed by Judge Ronnie Abrams on 7/28/2022) (kv)

July 26, 2022
VIA ECF
Honorable Ronnie Abrams
United States District Court
Southern District of New York
40 Foley Square, Room 2203
New York, NY 10007
RE:

99 Wall Development Inc. v. Allied World Specialty Insurance
Company f/k/a Darwin National Assurance Company
Civil Action No.: 1:18-cv-00126 (RA-KHP)

Dear Judge Abrams:
We represent Plaintiff, 99 Wall Development Inc. (“99 Wall”), in the above
referenced matter. The purpose of our letter is to respectfully request an extension of
time on 1) the production of the parties’ physical exhibits, 2) motions in limine. We are
joined in this letter by counsel for Defendant, Allied World Specialty Insurance Company
(“Allied”).
On June 2, 2022, Your Honor entered an Order setting the deadline for the
parties’ pretrial filings for August 3, 2022. The parties have been working to develop all
of their pretrial submissions. Given the volume of exhibits to be submitted, and the
recently recommenced settlement communications, the parties respectfully request an
extension of time on the submission of their physical trial exhibits with all remaining
pretrial deadlines to remain the same. Both parties are prepared to submit their exhibits
electronically and will do so by the current deadline, but respectfully request the Court
enter an Order allowing the parties to submit physical copies of their exhibits to the
Court and each other thirty (30) days in advance of the start date of trial.
Additionally, the parties respectfully request a seven (7) day extension to file their
motions in limine, which are currently also due on August 3, 2022. The new deadline
would be August 10, 2022. All other pretrial filings would remain due on August 3, 2022.
99 Wall thanks the Court for its time and consideration of this matter.
Respectfully submitted,
/s/ Stephanie A. Giagnorio
Stephanie A. Giagnorio, Esq.
[e-mail]
Saxe Doernberger & Vita, P.C.
999 Vanderbilt Beach Rd., Suite 603
Naples, FL 34108
35 Nutmeg Drive, Suite 140, Trumbull, CT 06611 • 203.287.2100
www.sdvlaw.com
Connecticut • Florida • California • New Jersey

T: [phone]
F: [phone]
Attorneys for Plaintiff, 99 Wall Development Inc
cc:

Counsel of Record via CM/ECF

Application granted.
The parties shall submit a joint letter by no later than
August 3, 2022 proposing potential dates for trial and
estimating its length.
SO ORDERED.

___________________________
Hon. Ronnie Abrams
07/28/2022

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