State Of New York et al v. Mnuchin et al

Filing 55

LETTER MOTION for Extension of Time for the Plaintiff States' Reply Brief addressed to Judge J. Paul Oetken from State of New York dated March 5, 2019. Document filed by State Of New York.(Olsen, Caroline)

STATE OF NEW YORK
OFFICE OF THE ATTORNEY GENERAL
LETITIA JAMES

BARBARA D. UNDERWOOD

ATTORNEY GENERAL

SOLICITOR GENERAL
DIVISION OF APPEALS & OPINIONS

March 5, 2019
BY ECF
The Honorable J. Paul Oetken
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
Re:

State of New York, et al. v. Mnuchin et al., No. 18-cv-6427 (JPO)

Dear Judge Oetken:
We write on behalf of the Plaintiff States of New York, Connecticut, Maryland, and
New Jersey in the above-captioned action. We write respectfully to request a one-week
extension of time to file the States’ upcoming reply brief in support of our cross-motion for
summary judgment. The States’ reply brief is currently due on March 15, 2019. See ECF No.
52. If granted, the reply brief would be due on March 22, 2019.
This extension is requested due to the professional obligations of the attorneys
principally responsible for preparing and reviewing the reply brief. The attorneys are
responsible for preparing multiple state and federal court briefs over the next three weeks,
including a brief in the U.S. Court of Appeals for the Second Circuit in Consumer Financial
Protection Bureau v. RD Legal, LLC, No. 18-2743, which is due on March 15, 2019. In
addition, two of the attorneys who are principally responsible for drafting the reply brief in
this case are preparing for a Second Circuit argument on March 8, 2019, in State of New York
v. United Parcel Service, Inc., No. 17-1993. Many of the deadlines that we are now facing
were set before or during the shutdown when we were unable to anticipate the revised
schedule in this case.
This is the first extension requested by Plaintiffs. Defendants have consented to the
proposed extension.

28 LIBERTY STREET, NEW YORK, NY 10005-1400 • PHONE [phone] • FAX [phone] *NOT FOR SERVICE OF PAPERS
WWW.AG.NY.GOV

Respectfully submitted,
LETITIA JAMES
Attorney General
State of New York
Attorney for the State of New York
By: . /s/ Caroline A. Olsen .
CAROLINE A. OLSEN
Assistant Solicitor General
BARBARA D. UNDERWOOD
Solicitor General
MATTHEW COLANGELO
Chief Counsel for Federal Initiatives
STEVEN C. WU
Deputy Solicitor General
ERIC R. HAREN
Senior Advisor and Special Counsel
OWEN T. CONROY
Assistant Attorney General
28 Liberty Street
New York, NY 10005
[phone]
cc: Counsel for Defendants (via ECF)

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