Upsolve, Inc. et al v. James

Filing 70

LETTER MOTION for Extension of Time to File Answer addressed to Judge Paul A. Crotty from Matthew J. Lawson dated May 31, 2022. Document filed by Letitia James..(Lawson, Matthew)

STATE OF NEW YORK
OFFICE OF THE ATTORNEY GENERAL

LETITIA JAMES

ATTORNEY GENERAL

DIVISION OF STATE COUNSEL

Writer’s Direct Dial: [phone]

LITIGATION BUREAU

May 31, 2022
By ECF
The Honorable Paul A. Crotty
United States District Judge
United States District Court
Southern District of New York
500 Pearl St.
New York, NY 10007
RE:

Upsolve, Inc. v. James, 22-CV-627 (PAC)

Dear Judge Crotty:
This Office represents the Attorney General in the above-captioned case. The current
deadline for the Attorney General to answer or otherwise respond to the complaint is June 3,
2022. See 2/01/22 Minute Entry (extending answer deadline until 10 days after decision on
Plaintiffs’ motion for a preliminary injunction). The Attorney General respectfully requests that
this deadline be extended until July 15, 2022.
The complaint in this matter contains 112 paragraphs, and an extension is needed so that
the Attorney General can properly respond to the pleaded allegations. An extension is also
appropriate given the important public policy issues at stake.
This is the Attorney General’s second request for an extension of its time to answer, as
this Office also orally requested a stay or extension of that deadline pending disposition of
Plaintiff’s preliminary injunction motion. Plaintiffs’ counsel consents to the requested extension,
and simply asked, in return, that the Attorney General consent to Plaintiffs’ forthcoming motion
to extend the deadline for filing the case management order until July 15, 2022. The Attorney
General agrees to this condition.

28 LIBERTY STREET, NEW YORK, NY 10005 ● PHONE [phone] ● WWW.AG.NY.GOV

Hon. Paul A. Crotty
May 31, 2022
Page 2

Thank you for your time and attention to this matter.
Respectfully submitted,
/s/ Matthew J. Lawson
Matthew J. Lawson
Assistant Attorney General

28 LIBERTY STREET, NEW YORK, NY 10005 ● PHONE [phone] ● WWW.AG.NY.GOV