Sivio v. Village Care Max
ORDER: granting 83 Letter Motion for Extension of Time to File. Extension to January 21, 2021 Granted. SO ORDERED. (Signed by Magistrate Judge Gabriel W. Gorenstein on 10/13/2020) (ama)
Case 1:18-cv-02408-GBD-GWG Document 83 Filed 10/12/20 Page 1 of 2
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JUAN C. GONZALEZ Partner
October 12, 2020
Hon. Gabriel W. Gorenstein
Chief U.S. Magistrate Judge
Daniel Patrick Moynihan
United States Court House
500 Pearl Street
New York, NY 10007-1312
Extension to January 21, 2021 granted.
October 13, 2020
Sivio, Enza v. Village Care Max
Docket No.: 1:18-civ-2408
Request for Extension of Time To Submit Joint Pre-Trial Order
I trust this finds you well during the pandemic. I write to request an extension of time to
file with plaintiff’s counsel the joint pre-trial order.
My office is newly-substituted counsel of record for the defendant, Village Care Max in
this matter. On August 3, 2020, your undersigned filed a Notice of Substitution of Counsel (Dkt
# 82), awaiting so-ordering by the Court. Prior counsel of record was the law firm of Littler
Mendelson, P.C. by way of Ms. Rebecca Goldstein, Esq. and Mr. Eric Witkin, Esq.
This extension request is on consent of plaintiff’s counsel and pursuant to Your Honor’s
Individual Rules of Practice 1(A) and 1(E). We request a ninety-day (90) extension of the parties’
time to file their Joint Pre-Trial Order, which is currently due by October 21, 2020 (see ECF Dkt.
# 81). The Order was originally due 2/21/20, initially extended upon plaintiff’s request to 3/21/20
(Dkt. #s 74-75), and thereafter extended via three requests by prior counsel (Littler Mendelson,
P.C.) (Dkt. #s 76-81).
We respectfully ask for the additional time due to our recent substitution and procurement
of the litigation file from outgoing counsel Littler Mendelson, P.C. so that we may have sufficient
time to review the voluminous record amassed in this case thus far through summary judgment,
which was decided earlier this year. Compounding the voluminous file to review in this matter is
the fact that my wife recently gave birth to our second child this past week. Although this has
been a welcomed distraction from work, as well as the current Covid-19 strains on work and
staffing issues – as I hope to be able to take a modest amount of time off to spend with my newborn
– a distraction nonetheless it will be.
Case 1:18-cv-02408-GBD-GWG Document 83 Filed 10/12/20 Page 2 of 2
Page 2 of 2
Finally, and perhaps most importantly, plaintiff’s counsel and I have been in discussions
on submitting this case for private mediation and are in the process of making plans for same in
an attempt to reach an amicable resolution without prolonged litigation.
As always, I thank the Court for its time, courtesies and consideration in this as in every
Juan C. Gonzalez
All Counsel of Record via ECF
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