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)

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: [phone]
FACSIMILE: [phone]
[e-mail]
[e-mail]
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