Oliver v. City of New York et al

Filing 221

ORDER granting 219 Letter Motion for Extension of Time to File. The Application is granted. SO ORDERED. (Signed by Judge Paul G. Gardephe on 11/15/2023) (ks)

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Case 1:19-cv-11219-PGG-JLC Document 219 Filed 11/14/23 Page 1 of 2 THE CITY OF NEW YORK HON. SYLVIA O. HINDS-RADIX Corporation Counsel LAW DEPARTMENT 100 CHURCH STREET NEW YORK, NY 10007 CHRISTOPHER G. ARKO Senior Counsel phone: (212) 356-5044 carko@law.nyc.gov November 14, 2023 BY ECF The Honorable Paul G. Gardephe United States District Judge Southern District of New York 40 Foley Square New York, NY 10007 Re: Akeem Oliver v. City of New York, et al., 19 Civ. 11219 (PGG)(JLC) Your Honor: I am a Senior Counsel in the New York City Law Department, one of the attorneys representing defendants City of New York, Board of Education of the City School District of the City of New York (“DOE”), Sonhando Estwick, Carry Chan, and Kristine Mustillo (“the DOE defendants”) in the above-referenced matter. I write along with Omar Siddiqi, Esq., counsel for defendants Kenneth Taylor, Kevin McLeod, and Tong Jiang (“the NYPD defendants”) to respectfully request an extension, from November 16, 2023 to November 30, 2023, for defendants to serve plaintiff with their summary judgment motion. Plaintiff consents to this extension and the following amended briefing schedule: defendants’ summary judgment motion to be served November 30, 2023; any opposition from plaintiff to be served January 5, 2024; and defendants’ reply to be served January 26, 2024. The reasons for this request are set forth below. Co-counsel for the DOE defendants Maria DeCastro, Esq., has unexpectedly been out sick since last week with COVID. Ms. DeCastro was briefing several motion points for the DOE defendants’ memorandum of law, which she has been unable to complete. Further, all defense counsel must be able to work together to finalize defendants’ declaration and supporting exhibits, Local Civil Rule 56.1 statement, and memorandum of law. As the Court is aware, next Thursday is Thanksgiving. I will be out of the office from November 21 through November 24 on a previously scheduled vacation, Ms. DeCastro will be out of the office all next week on a previously scheduled vacation, and Mr. Siddiqi will be out of the office from November 22 until November 28 on a previously scheduled vacation. Case 1:19-cv-11219-PGG-JLC Document 219 Filed 11/14/23 Page 2 of 2 Defendants thank the Court for its consideration herein. Respectfully submitted, /s/ Christopher G. Arko Christopher G. Arko Senior Counsel Date: November 15, 2023 2

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