Bahadoran v. City Of New York et al

Filing 89

ORDER granting 88 Letter Motion for Extension of Time to File. Application GRANTED. But given that more than six months have passed since the Court ruled on Defendants' motion for summary judgment, no further extensions will be granted. The Court will set a trial date upon the filing of a proposed JPTO; the parties should be prepared to try the case as soon as two weeks thereafter. The Clerk is directed to terminate ECF No. 88.SO ORDERED. (Signed by Judge Jesse M. Furman on 5/9/24) (yv)

THE CITY OF NEW YORK

LAW DEPARTMENT

HON. SYLVIA O. HINDS-RADIX
Corporation Counsel

100 CHURCH STREET
NEW YORK, NY 10007

MARY O’FLYNN
Senior Counsel
Phone: [phone]
Fax: [phone]
[e-mail]

May 8, 2024
VIA E.C.F.
Honorable Jesse M. Furman
United States District Court
Southern District of New York
500 Pearl Street
New York, New York 11201
Re:

Bahadoran v. City of New York et al.
21-cv-04884 (JMF)

Your Honor:
I am a Deputy Chief in the Special Federal Litigation Division of the New York
City Law Department and supervising the above-referenced matter of behalf of defendants. I
write to respectfully request a 30 day extension of the deadline to submit the Joint Pretrial Order
and other associated pretrial materials from May 24, 2024 to June 24, 2024. We have conferred
with Plaintiff’s counsel and they take no position on this request.
As the Court is already aware, this is a complex case which concerns a police
shooting resulting in serious injuries to plaintiff (partial paralysis). The parties have spent a
substantial amount of time and effort exploring potential settlement which was ultimately
unsuccessful. We are now in the process of assigning one of our trial team attorneys to this case.
Our trial team attorney is currently engaged in a death in custody trial that began yesterday and is
expected to last three weeks. That attorney would need sufficient time to familiarize themself
with this case so they can meaningfully contribute to the pretrial submission. In addition, because
many of the pretrial documents are to be jointly submitted the current schedule leaves very little
room for the parties to prepare their respective portions of those submissions and have a
productive dialogue and exchange about same.

Accordingly, it is respectfully requested that the Court grant a 30 day enlargement
of time, until June 24, 2024, to submit the Joint Pretrial Order and other associated pretrial
materials in this matter.
We thank the Court for its consideration of this request.

Respectfully submitted,
s/ Mary O’Flynn
Deputy Chief
Special Federal Litigation

cc:

All counsel of record (by E.C.F.)

Application GRANTED. But given that more than six months have passed since the Court ruled
on Defendants' motion for summary judgment, no further extensions will be granted. The Court
will set a trial date upon the filing of a proposed JPTO; the parties should be prepared to try the
case as soon as two weeks thereafter. The Clerk is directed to terminate ECF No. 88.
SO ORDERED.

May 9, 2024

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