Kilpatrick v. National Railroad Passenger Corp.

Filing 29

ORDER granting 28 Letter Motion for Discovery. Application GRANTED. SO ORDERED. (Signed by Judge Valerie E. Caproni on 5/9/2022) (tg)

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Case 1:20-cv-05870-VEC Document 29 Filed 05/09/22 Page 1 of 2 DANIEL J. “DANNY” POOLSON, JR. *† CARISA RENÉE GERMAN-ODEN * ALSO LICENSED IN MISSISSIPPI † ALSO LICENSED IN TEXAS MEMO ENDORSED Via ECF Electronic Filing The Honorable Valerie Caproni USDC, Southern District of New York 40 Foley Square New York, NY 10007 Re: May 5, 2022 ONE LAKEWAY 3900 N. CAUSEWAY BLVD., STE. 680 METAIRIE, LOUISIANA 70002 OFFICE: (504) 766-2200 FACSIMILE: (504) 766-2070 DANNY@POOLSONODEN.COM CARISA@POOLSONODEN.COM WWW.POOLSONODEN.COM USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 5/9/2022 Kilpatrick v. Amtrak USDC, SDNY, No. 1:20-cv-05870; P|O File No. 20-1048 Dear Judge Caproni, Pursuant to your Individual Practices in Civil Cases (1)(C), Requests for Adjournments or Extensions of Time, Plaintiff respectfully requests a brief continuance of the current deadline for fact discovery in this matter to complete one remaining deposition in the matter. As outlined in your Individual Practices, we submit the following: Under the updated Scheduling Order, all fact discovery must be completed by May 4, 2022, with a Pre-trial conference on June 17, 2022 (R. Doc. 27). All expert discovery, including reports, production of underlying documents and depositions, is scheduled to be completed by June 15, 2022. Plaintiff requests a brief extension of the discovery deadline to complete the deposition of Ms. Francis Williams. The deposition of Ms. Williams was scheduled for May 3, 2022. However, undersigned counsel had an uncurable conflict and requested additional deposition dates from Amtrak’s counsel. Amtrak’s counsel is currently procuring additional dates. Further, Amtrak is supplementing discovery with documents requested by Plaintiff’s counsel for Ms. Williams’ deposition. Amtrak does not have an objection to this brief extension. Plaintiff is requesting a brief fact discovery continuance until the date of the mediation in this case, June 3, 2022, to complete the deposition of Ms. Williams. Please let me know if there is any further information that you require. Thank you for your time and attention to this matter, and with kind regards, I remain Very truly yours, CGO/klw cc: Mina Miawad Carisa German-Oden Case 1:20-cv-05870-VEC Document 29 Filed 05/09/22 Page 2 of 2 Application GRANTED. SO ORDERED. Date: 5/9/2022 HON. VALERIE CAPRONI UNITED STATES DISTRICT JUDGE

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