Reneyda Cuello v. Healthfirst PHSP, Inc.

Filing 23

ORDER granting 22 Letter Motion to Adjourn Conference. APPLICATION GRANTED: The telephonic Initial Case Management Conference scheduled for Wednesday, April 28, 2021 at 11:00 a.m. is hereby rescheduled to Wednesday, June 2, 2021 at 3:30 p.m. Counsel for the parties are directed to call Judge Parker's court conference line at the scheduled time. Please dial [phone], Access code: 4858267. Initial Conference set for 6/2/2021 at 03:30 PM before Magistrate Judge Katharine H. Parker. (Signed by Magistrate Judge Katharine H. Parker on 4/26/2021) (mro)

LAW OFFICES OF G. OLIVER KOPPELL & ASSOCIATES

G. Oliver Koppell
___
Daniel F. Schreck
Daniel Casados

99 Park Avenue – Suite 1100
New York, NY 10016
212-867-3838
____
Facsimile
[phone]
____
Website:
www.koppellaw.com

of Counsel:
Lorraine Coyle
Ruth Jin

04/26/2021

April 23, 2021
Via ECF
Honorable Magistrate Judge Katharine H. Parker
United States District Court – Southern District of New York
Daniel Patrick Moynihan – United States Courthouse
500 Pearl Street
New York, New York, 10007
Re:
Eusebia Reneyda Cuello v. Healthfirst PHSP, Inc., No. 20-CV-10177 (JPO)
Request for an Adjournment of Case Management Conference & Fact Discovery Due Dates
Dear Magistrate Judge Parker:
I am counsel for Plaintiff Cuello in the above-referenced matter. I write to you with
Defendant’s consent pursuant to your Individual Rules to seek an adjournment of the April 28,
2021, case management conference and the fact discovery due dates.
This is my second request for an adjournment. The first request was due to a scheduling
conflict, and the Court granted the adjournment. I seek this adjournment because currently all
fact discovery, including depositions, are due by June 16, 2021, which I will not be able to meet.
My practice experienced a very busy month of April and, forthcoming, will experience an
equally busy month of May.
If your honor would prefer that these fact discovery due dates be addressed at the April
28, 2021, conference, counsels will be present. Otherwise, I request that the conference and due
dates be moved back by five weeks, whereby the conference would be held on June 2, 2021, and
the fact discovery deadlines, including depositions, be moved to July 21, 2021. Defendant’s
counsel consents to these proposed dates. Yet, if these proposed conference and discovery dates
do not work for the Court, I request that the Court select the dates.
I thank you for your consideration.
Respectfully submitted,
/s/ G. Oliver Koppell
G. Oliver Koppell

LAW OFFICES OF G. OLIVER KOPPELL & ASSOCIATES

G. Oliver Koppell
___
Daniel F. Schreck
Daniel Casados

99 Park Avenue – Suite 1100
New York, NY 10016
212-867-3838
____
Facsimile
[phone]
____
Website:
www.koppellaw.com

of Counsel:
Lorraine Coyle
Ruth Jin

Cc: David Warner, Esq., via ECF

APPLICATION GRANTED: The telephonic Initial Case Management
Conference scheduled for Wednesday, April 28, 2021 at 11:00 a.m. is hereby
rescheduled to Wednesday, June 2, 2021 at 3:30 p.m. Counsel for the parties
are directed to call Judge Parker’s court conference line at the scheduled time.
Please dial [phone], Access code: 4858267.

04/26/2021