Cid Hurtado et al v. Hudson Fulton Corp. et al

Filing 71

ORDER: granting in part 70 Letter Motion to Adjourn Conference; granting in part 70 Letter Motion for Extension of Time to Complete Discovery. Plaintiffs' letter-motion seeking to adjourn the status conference scheduled for Tuesday, Novemb er 22, 2022 at 4:00 p.m. and extend the fact discovery deadline (ECF No. 70) is GRANTED IN PART, and the Conference is ADJOURNED sine die. The fact discovery deadline is extended to Friday, December 30, 2022, and the parties shall file a joint letter certifying the completion of fact discovery by Friday, January 6, 2022. The Clerk of Court is respectfully directed to close ECF No. 70. SO ORDERED.. (Signed by Magistrate Judge Sarah L Cave on 11/21/2022) (ama)

Case 1:20-cv-09133-RA-SLC Document 71 Filed 11/21/22 Page 1 of 2

MORRISON-TENENBAUM PLLC, ATTORNEYS-AT-LAW M-T-LAW.COM
87 WALKER STREET 2ND FLOOR NEW YORK NY 10013
PHONE [phone] FAX [phone]

November 21, 2022
VIA ECF
Honorable Sarah L. Cave
United States District Court, Southern District of New York
500 Pearl Street
New York, NY 10007
Re: Hurtado v. Hudson Fulton Corp., No. 20-cv-9133 (RA) (SLC)
Dear Judge Cave:
We are counsel for the Plaintiffs in this action. We write to respectfully request that the
discovery deadline be extended from November 23, 2022 to January 16, 2023, and that the
conference scheduled for Tuesday November 22, 2022 be adjourned, or held by telephone.
The reason for the request is that discovery has not been completed and is not able to be
completed by November 23, 2022. As an update to the status of discovery, Defendant Thomas
Bosco has responded to discovery requests and was deposed on November 18. Defendant Jason
Minter, who is pro se, has provided the pay records referenced in the October 12, 2022 conference
and order, but has not responded to written discovery, including interrogatories, document
requests, and requests for admission. I had noticed his deposition for November 23, 2022, but Mr.
Minter has advised that he is unable to attend a deposition on that date due to work obligations,
but would be available in mid or late December. Given that Mr. Minter still needs to respond to
discovery requests and be deposed, we respectfully request an extension of the discovery deadline.
We also respectfully request an adjournment of the November 22, 2022 conference, or ask
that it be held by telephone. The request is in part due to our request to extend discovery.
Additionally, I emailed Mr. Minter last night to remind him of the conference, and he advised that

Case 1:20-cv-09133-RA-SLC Document 71 Filed 11/21/22 Page 2 of 2

he was not aware of the date and time of the conference, and that he would be unable to attend
without significant difficulty due to his work schedule and his wife’s recovering from surgery. I
therefore request jointly with Mr. Minter that the conference be adjourned or changed to a
telephone conference.
This is the second request to adjourn the conference. It was previously adjourned at my
request from November 21 to November 22. All parties consent to the adjournment.
We thank Your Honor for your attention to this matter.
Respectfully submitted,
/s/ Joshua S. Androphy
Joshua S. Androphy, Esq.

Plaintiffs' letter-motion seeking to adjourn the status conference
scheduled for Tuesday, November 22, 2022 at 4:00 p.m. and
extend the fact discovery deadline (ECF No. 70) is GRANTED IN
PART, and the Conference is ADJOURNED sine die. The fact
discovery deadline is extended to Friday, December 30, 2022, and
the parties shall file a joint letter certifying the completion of fact
discovery by Friday, January 6, 2022.
The Clerk of Court is respectfully directed to close ECF No. 70.
SO ORDERED 11/21/22