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)

Download PDF
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 (212) 416-8020 • FAX (212) 416-8962 *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 (212) 416-6184 cc: Counsel for Defendants (via ECF) 2

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?