Lopes v. JLM Decorating NYC Inc et al

Filing 77

ORDER granting 76 Letter Motion for Extension of Time to File. Defendant having shown compelling circumstances, the application is GRANTED. The parties shall file the proposed Joint Pre-Trial Order no later than December 17, 2021. SO ORDERED. (Signed by Magistrate Judge Barbara C. Moses on 11/18/2021) (vfr)

Case 1:20-cv-00314-BCM Document 77 Filed 11/18/21 Page 1 of 3
Defendant having shown compelling
THE LAW OFFICE OF JON A. STOCKMAN circumstances, the application is
32 Broadway, Suite 1710
GRANTED. The parties shall file the
New York, NY 10004
proposed Joint Pre-Trial Order no later
www.yournycattorney.com
than December 17, 2021. SO
Telephone: [phone]
ORDERED.
Fax: [phone]
Email: [e-mail]
11/18/2021
November 17, 2021
Via ECF
Hon. Barbara Moses
United States District Court
500 Pearl St., Courtroom 20A
New York, NY 10007-1312

_________________________
Barbara Moses, U.S.M.J.
November 18, 2021

Re: Angelo Lopes v. JLM Decorating NYC Inc et al., 20-cv-00314-BCM
Your Honor:
I represent Plaintiff in the above referenced matter. I write this letter at the request of
Defendants’ counsel. Defendants request an extension of the parties’ deadline to submit their
proposed Joint Pre-Trial Order from November 22, 2021 until December 10, 2021 or December
17, 2021. Plaintiff consents to Defendants’ request.
On November 16, 2021, I emailed opposing counsel Plaintiff’s portion of the proposed
Joint Pre-Trial. The day prior, I had also emailed opposing counsel a list of facts that I propose
the parties stipulate to. On November 16, 2021, I sent opposing counsel an email asking him if he
was available to discuss the Joint Pre-Trial Order today (November 17). This morning, at or around
9:23 am, I sent opposing counsel a text message asking him if he could talk this afternoon.
Opposing counsel’s response is attached hereto as Exhibit A.
This is the third request for an extension of the deadline to submit the proposed Joint PreTrial Order. The Court granted the two prior requests, but explained in its last Order that “[n]o
further extensions will be granted absent compelling circumstances.”
If the Court grants the instant request, this will affect the conference scheduled for
November 29, 2021. I am available every day in December except for December 16 and December
29. As of the time of this filing, opposing counsel hasn’t provided me with proposed adjourn dates.
Opposing counsel’s away message indicates that he will be “out of the office with limited access
to emails from 11/17 to 12/3, returning to the office on Monday 12/5.”
In the absence of an Order extending the parties’ deadline to submit their proposed Joint
Pre-Trial Order, Plaintiff intends to file his portion by November 22, 2021 (the current deadline)
regardless of whether Defendants participate.
Respectfully submitted,
/S/Jon A. Stockman, Esq.
cc: Brett W. Joseph, Esq.

Case 1:20-cv-00314-BCM Document 77 Filed 11/18/21 Page 2 of 3

EXHIBIT A

Case 1:20-cv-00314-BCM Document 76 Filed 11/17/21 Page 3 of 3
77
11/18/21