Massey v. Morgan
Filing
73
ORDER granting 72 Letter Motion for Extension of Time to File. So Ordered. (Signed by Judge Andrew L. Carter, Jr on 1/20/2021) (js)
Case 1:18-cv-03994-ALC-KHP Document 73 Filed 01/20/21 Page 1 of 2
January 20, 2021
THE CITY OF NEW YORK
LAW DEPARTMENT
JAMES E. JOHNSON
Corporation Counsel
100 CHURCH STREET
NEW YORK, NY 10007
STEFANO PÉREZ
Assistant Corporation Counsel
phone: (212) 356-2381
fax: (212) 356-3509
sperez@law.nyc.gov
January 19, 2021
VIA ECF
Honorable Katharine H. Parker
United States Magistrate Judge
United States District Court
Southern District of New York
500 Pearl Street, Room 750
New York, New York 10007-1312
Re:
Tyrone Massey v. Captain Josette Morgan,
18-CV-3994 (ALC) (KHP)
Your Honor:
As the attorney assigned to the defense of this matter, I write to respectfully
request a brief two-week extension of time within which defendant may serve its opposition to
plaintiff’s motion for summary judgment and its anticipated cross-motion for summary judgment
from January 22, 2021 to February 5, 2021; and (2) a corresponding extension of the time within
which plaintiff is to serve his reply from February 14, 2021 to March 1, 2021. This application
is made without plaintiff’s consent, as plaintiff, who appears pro se, is incarcerated and thus,
cannot be reached expeditiously. This is defendant’s first request for an extension of time to file
its opposition and cross-motion.
As Your Honor knows, plaintiff asserts a claim against defendant for deliberate
indifference to plaintiff’s serious medical needs. On December 15, 2020, plaintiff filed a motion
for summary judgment consisting of 62 pages. Due to the holidays, the undersigned’s mandatory
furlough days, and pre-existing legal commitments in other matters, I will not be able to
complete defendant’s opposition and cross-motion by the current due date of January 22, 2021.
Accordingly, defendant respectfully seeks a brief two-week enlargement from
January 22, 2021 to February 5, 2021, to file its opposition and cross-motion.
Thank you for your consideration herein.
Respectfully submitted,
Stefano Pérez
January 20, 2021
S/
____________
Stefano Pérez
Assistant Corporation Counsel
Special Federal Litigation Division
Case 1:18-cv-03994-ALC-KHP Document 73 Filed 01/20/21 Page 2 of 2
cc:
BY FIRST CLASS MAIL
Tyrone Massey
Book and Case No. 8952000522
Plaintiff Pro Se
Manhattan Detention Complex
125 White Street
New York, New York 10013
2
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