Upsolve, Inc. et al v. James

Filing 59

LETTER MOTION for Extension of Time to File Response/Reply (Extension of time to submit a reply in support of Plaintiffs' Motion for a Preliminary Injunction) addressed to Judge Paul A. Crotty from Gregory Silbert dated April 18, 2022., LETTER MOTION for Oral Argument (Court schedule oral argument on the Motion) addressed to Judge Paul A. Crotty from Gregory Silbert dated April 18, 2022. Document filed by Rev. John Udo-Okon, Upsolve, Inc...(Silbert, Gregory)

BY ECF

April 18, 2022

767 Fifth Avenue
New York, NY 10153-0119
[phone] tel
[phone] fax
Gregory Silbert
[phone]
[e-mail]

Hon. Paul A. Crotty
United States District Court
Southern District of New York
500 Pearl Street, Chambers 1350
New York, New York 10007
Re: Upsolve, Inc., et al., v. James, 22-CV-627 (PAC)
Dear Judge Crotty:
We represent Plaintiffs Upsolve, Inc., and Rev. John Udo-Okon in connection with the abovereferenced matter. We write to respectfully request: 1) a brief extension of time to submit a reply in
support of Plaintiffs’ Motion for a Preliminary Injunction (ECF 5, the “Motion”), and 2) that the
Court schedule oral argument on the Motion.
First, Plaintiffs request a brief extension of time to Monday, May 2, 2022, to file a reply brief
in support of the Motion. Defendant consents to Plaintiffs’ requested extension. Granting Plaintiffs
request is fully consistent with the briefing schedule initially established by the Court. Following the
scheduling conference of February 1, 2022, the Court ordered that Defendant’s opposition to the
motion would be due by Friday, March 11, 2022, and Plaintiff’s reply would be due just over two
weeks later on Monday, March 28, 2022. The Court subsequently extended the deadline for
Defendant’s opposition brief to Monday, April 18, 2022. At that time, however, the Court did not
extend the deadline of Plaintiffs’ reply. In light of the significance and complexity of the issues raised
and for all of the reasons that originally justified the Court’s ordering of a two-week reply window,
Plaintiffs accordingly seek an extension to preserve the Court’s previously ordered timing. This is
Plaintiffs’ first request for an extension in this matter.
Second, Plaintiffs also request that the Court schedule oral argument on the Motion under
Rule 3.K of Your Honor’s Individual Practices in Civil Cases. Argument is justified given the
significance and complexity of the issues the Motion raises.
Respectfully submitted,
/s/ Gregory Silbert
Gregory Silbert
cc: Counsel of Record (via ECF)