A.P. et al v. New York City Department of Education
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)
THE CITY OF NEW YORK
HON. SYLVIA O. HINDS-RADIX
100 CHURCH STREET
NEW YORK, NY 10007
HANNAH J. SAROKIN
phone: (212) 356-8761
July 28, 2022
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
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.
Hannah J. Sarokin
Assistant Corporation Counsel
Kevin M. Mendillo, Esq. (via ECF)
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?