Rowe v. Google LLC

Filing 11

ORDER denying in part 10 LETTER MOTION to Adjourn Conference and Proposed Schedule. Application DENIED IN PART. The Court does not ordinarily adjourn initial pretrial conferences pending an amended complaint. The initial pretrial conference, sched uled for November 21, 2019, is adjourned to December 5, 2019, at 10:40 a.m. The parties shall file the joint letter and proposed Case Management Plan and Scheduling Order by November 28, 2019. The parties shall otherwise comply with the schedule prop osed herein: Plaintiff shall file the First Amended Complaint by November 22, 2019, Defendant shall file its answer by December 6, 2019, the parties shall complete the initial discovery required by the pilot discovery protocols by January 7, 2020 and the parties shall complete mediation by February 14, 2020. Initial Conference set for 12/5/2019 at 10:40 AM before Judge Lorna G. Schofield. (Signed by Judge Lorna G. Schofield on 11/19/2019) (jca)

USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 11/19/2019

Via ECF
The Honorable Lorna G. Schofield
United States District Judge
Southern District of New York
500 Pearl Street, Chambers 1350
New York, NY 10007
Re:

Ulke Rowe v. Google LLC, Case No. 1:19-cv-08655-LGS

Dear Judge Schofield:
Counsel for Plaintiff and Defendant jointly write to request an adjournment of the
preliminary conference in this case, which is currently scheduled for November 21, 2019 at
10:40 a.m., as well as the Court’s related order that the Parties file their joint letter and proposed
Case Management Plan and Scheduling Order no later than November 18, 2019 at 10:00 a.m.
Plaintiff has received a Notice of Right to Sue from the Equal Employment Opportunity
Commission and, consequently, intends to file an amended complaint in this action.
Additionally, this case is subject to the Second Amended Standing Administrative Order, 11Misc-003 (S.D.N.Y. Oct. 1, 2015) and the Initial Discovery Protocols for Employment Cases
Alleging Adverse Action. An adjournment will promote efficiency as the information and
documents exchanged in the initial discovery will aid the Parties in drafting the case
management plan and scheduling order, as contemplated by the Standing Order incorporated into
the Initial Discovery Protocols for Employment Cases Alleging Adverse Action. This is the
Parties’ first request for an adjournment.
The Parties have conferred and stipulated to the following schedule and respectfully
request that the Court So Order the Proposed Schedule.
Plaintiff to File First
Amended Complaint
Defendant to File Answer to
Plaintiff’s First Amended
Complaint
Completion of Initial
Discovery pursuant to Pilot
Project Protocols

Original Date:

Proposed Date:
November 22, 2019
December 6, 2020
January 7, 2020

The Honorable Lorna G. Schofield
November 15, 2019
Page 2 of 2
Filing of joint letter and
proposed Case Management
Plan and Scheduling Order
Preliminary Conference
Completion of Meditation

January 13, 2020
November 21, 2019

On or after January 13, 2020
February 14, 2020

Respectfully submitted,

Kenneth W. Gage
Paul Hastings LLP
200 Park Avenue
New York, NY 10166
Counsel for the Defendant

Cara E. Greene
Outten & Golden LLP
685 Third Avenue, 25th Floor
New York, NY 10017
Counsel for the Plaintiff

cc: All parties (via ECF)
Application DENIED IN PART. The Court does not ordinarily adjourn initial pretrial
conferences pending an amended complaint.
The initial pretrial conference, scheduled for November 21, 2019, is adjourned to
December 5, 2019, at 10:40 a.m. The parties shall file the joint letter and proposed Case
Management Plan and Scheduling Order by November 28, 2019.
The parties shall otherwise comply with the schedule proposed herein: Plaintiff shall file the
First Amended Complaint by November 22, 2019, Defendant shall file its answer by
December 6, 2019, the parties shall complete the initial discovery required by the pilot
discovery protocols by January 7, 2020 and the parties shall complete mediation by
February 14, 2020.
Dated: November 19, 2019
New York, New York