Government Employees Insurance Company v. United States of America

Filing 18

MEMO ENDORSEMENT on re: 17 granting 15 Letter Motion to Adjourn Conference. ENDORSEMENT: The conference scheduled for January 12, 2022 is adjourned to February 18, 2022 at 3:30 pm. The parties shall submit their proposed case management plan and joint letter by February 9, 2022. SO ORDERED. Initial Conference set for 2/18/2022 at 3:30 PM before Judge Alison J. Nathan. (Signed by Judge Alison J. Nathan on 1/7/2022) (vfr)

Case 1:21-cv-07828-AJN Document 17 Filed 01/05/22 Page 1 of 2
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01/07/22
U.S. Department of Justice
United States Attorney
Southern District of New York
1/7/2022
VIA ECF
The Honorable Alison J. Nathan
United States District Judge
Thurgood Marshall United States Courthouse
40 Foley Square
New York, NY 10007-1312
Re:

86 Chambers Street
New York, New York 10007

January 5, 2022

Government Employees Insurance Company as subrogee of Luis Feliz v. United
States of America, 21-cv-7828 (AJN)

Dear Judge Nathan:
This Office represents defendant United States of America (the “Government”) in the
above-referenced subrogation action by plaintiff Government Employees Insurance Company as
subrogee of Luis Feliz (“Plaintiff”), under the Federal Tort Claims Act, 28 U.S.C. §§ 1346(b),
2671 et seq. On December 29, 2021, the Government filed a letter-motion respectfully
requesting a 30-day extension of its time to answer the complaint, see ECF No. 14, which was
granted on January 3, 2022, see ECF No. 16. On December 29, 2021, the Government also filed
a supplemental letter-motion requesting a concomitant adjournment of the initial conference
from January 12, 2022, to a time that is convenient for the Court and the parties following the
Government’s extended deadline to respond to the complaint. See ECF No. 15. The Court has
not yet ruled on the latter request. If the conference adjournment request is not granted, a
proposed case management plan and joint letter are due today. See Order dated October 15,
2021 (ECF No. 10). Counsel respectfully request clarification from the Court as to whether the
conference currently scheduled for January 12 will proceed as scheduled or be adjourned. If it is
to proceed on January 12, in light of these circumstances, counsel respectfully request a two-day
adjournment of the deadline to file a proposed case management plan and joint letter in advance
of the conference.
I thank the Court for its consideration of this request.

The conference scheduled for
January 12, 2022 is adjourned to
February 18, 2022 at 3:30 pm. The
parties shall submit their proposed
case management plan and joint
letter by February 9, 2022.

1/7/2022

Case 1:21-cv-07828-AJN Document 17 Filed 01/05/22 Page 2 of 2
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01/07/22

Respectfully,
DAMIAN WILLIAMS
United States Attorney for the
Southern District of New York
By:

Cc:

/s/ Carly Weinreb
CARLY WEINREB
Assistant United States Attorney
86 Chambers Street, Third Floor
New York, NY 10007
Tel: [phone]
[e-mail]
Counsel for Defendant

Richard L. Elem, Esq., Counsel for Plaintiff (by ECF)

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