Flynn et al v. Cable News Network, Inc.

Filing 229

ORDER granting 228 Letter Motion for Extension of Time to File. SO ORDERED. (Signed by Judge Arun Subramanian on 5/9/2024) (vfr)

Case 1:21-cv-02587-AS-SLC Document 228 Filed 05/09/24 Page 1 of 2
21st Floor
1251 Avenue of the Americas
New York, NY 10020
Katherine M. Bolger
212.489.8230 tel
212.489.8340 fax
[e-mail]

May 9, 2024
VIA ECF
Hon. Arun Subramanian
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St. Courtroom 15
New York, NY 10007-1312

Re:

Flynn et al, v. Cable News Network, Inc., No. 1:21-cv-02587-AS-SLC

Dear Judge Subramanian:
We represent Defendant Cable News Network Inc. (“CNN”) in the above-referenced
action. We write to request a brief extension of time to file CNN’s application for fees pursuant
to Federal Rule of Civil Procedure 54(d) to recover reasonable attorneys’ fees and costs under
the fee-shifting provision in Rhode Island’s invasion of privacy statute, R.I. Gen. Laws § 9-128.1(b).
This Court granted CNN’s motion to for summary judgment in this action on April 24,
2024, and entered Judgment for CNN on April 25, 2024. According to Rule 54, CNN’s fee
petition would be due today, May 9, 2024. CNN respectfully requests three business days, until
May 14, to file the petition because of the complexity of reviewing, redacting and attaching the
correct billing records for this litigation, which has lasted for three years. In particular, as this
Court is aware, there are two related litigations pending in the United States District Court for
the Middle District of Florida and by agreement of the parties and with the awareness of the
Court, the parties consolidated discovery in all three matters. My office is endeavoring to review
the records to ensure that the correct amount of fees and costs be attributed to this matter and that
is taking some time.
CNN has not previously requested this extension, and there are no pending deadlines that
would be affected by this request. Plaintiffs do not object to this request. Thank you for your
consideration.
SO ORDERED.

4857-8595-1933v.1 0026517-000210

Arun Subramanian, U.S.D.J.
Date: May 9, 2024

Case 1:21-cv-02587-AS-SLC Document 228 Filed 05/09/24 Page 2 of 2
Hon. Arun Subramanian
May 9, 2024
Page 2
Respectfully submitted,
Davis Wright Tremaine LLP
/s/ Katherine M. Bolger
Katherine M. Bolger

cc:

Counsel of Record (via ECF)

4857-8595-1933v.1 0026517-000210