Zakaiem v. Ohanissian et al.

Filing 32

ORDER granting 31 Letter Motion for Extension of Time to Complete Discovery; granting 31 Letter Motion for Discovery. APPLICATION GRANTED: Counsel isdirected to file a Status letter in January. APPLICATION GRANTED. (Signed by Magistrate Judge Katharine H. Parker on 11/18/2021) (rro)

Case 1:21-cv-00074-KHP Document 32 Filed 11/18/21 Page 1 of 1
Efrem Schwalb
[e-mail]
500 Seventh Avenue, 8th Floor
New York, New York 10018
T: 646.553.1590
F: 646.553.1591
www.koffskyschwalb.com

11/18/2021
November 18, 2021

APPLICATION GRANTED: Counsel is
directed to file a Status letter in January.

BY ECF
The Honorable Katherine H. Parker
United States District Court, Southern District of New York
500 Pearl Street
New York, NY 10007-1312
Re:

Zakaiem v. Ohanissian et al, Civil Action No. 1:21-cv-00074-PAE-KHP

11/18/2021

Dear Judge Parker:
We recently appeared on behalf of defendants and write on behalf of both parties to request
two items of relief. First, the parties request the entry of the attached confidentiality order that we
have agreed upon to govern the exchange of confidential documents in this action. Second,
because the action was stayed and the exchange of documents is occurring shortly, the parties
request that the deadline for fact discovery be extended by four months from November 15, 2021
to March 15, 2022.
Thank you for your consideration.
Respectfully Submitted,

Efrem Schwalb
cc:

All counsel of record (By ECF)