A.P. et al v. New York City Department of Education

Filing 30

ORDER granting 29 Letter Motion for Extension of Time to File. Application GRANTED. The proposed briefing schedule is so ordered. (Signed by Judge Lorna G. Schofield on 7/29/22) (yv)

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THE CITY OF NEW YORK LAW DEPARTMENT HON. SYLVIA O. HINDS-RADIX Corporation Counsel 100 CHURCH STREET NEW YORK, NY 10007 HANNAH J. SAROKIN phone: (212) 356-8761 email: hsarokin@law.nyc.gov July 28, 2022 By ECF Honorable Lorna G. Schofield United States District Court Southern District of New York 500 Pearl Street New York, New York 10007 Application GRANTED. The proposed briefing schedule is so ordered. Dated: July 29, 2022 New York, New York Re: A.P. individually and on behalf of C.P. v. N.Y.C. Dept. of Educ. 21-cv-11157 (LGS) (VF) Dear Judge Schofield: I am an Assistant Corporation Counsel in the Office of the Corporation Counsel assigned to represent the New York City Department of Education (DOE) in the above-captioned matter, in which Plaintiff seeks attorneys’ fees pursuant to the fee-shifting provision of the Individuals with Disabilities Education Act, 20 U.S.C. § 1400, et seq. I write, with Plaintiff’s consent, to respectfully request a two-week extension of Defendant’s time to file its cross-motion for summary judgment, from August 1, 2022 until August 15, 2022. This is Defendant’s second request for an extension of time to file its cross-motion for summary judgment. On June 16, 2022, the parties jointly requested an extension of the summary judgment briefing schedule (ECF 24), including a nunc pro tunc extension of the parties’ time to file a Joint 56.1 Statement of Undisputed Facts and the underlying bates stamped administrative record, to allow the parties additional time to explore the possibility of settlement. The Court granted that request on June 24, 2022 (ECF 28). Defendant now respectfully requests a two-week extension of its time to file its cross-motion for summary judgment. The requested extension is on account of the recent departure of several senior attorneys from my office and multiple unanticipated and emergency deadlines and appearances that have recently arisen. Additionally, Plaintiff provided updated billing records on June 30, 2022, and Defendant made an offer of settlement on July 27, 2022. The additional time would allow the parties to consider to explore the possibility of settlement of this action without further need for judicial intervention. Accordingly, Defendant respectfully requests a two-week extension to the summary judgment briefing schedule, and respectfully proposes the following proposed briefing schedule: • • • Defendant shall file its cross motion by August 15, 2022; Plaintiff shall file her response by September 5, 2022; Defendant shall file its reply by September 19, 2022. Thank you for your consideration of this request. Respectfully submitted, /s/ Hannah J. Sarokin Assistant Corporation Counsel cc: Kevin M. Mendillo, Esq. (via ECF) Plaintiff’s counsel 2

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