M.W. et al v. New York City Department of Education
Filing
20
ORDER granting 19 Letter Motion for Extension of Time to Answer re 19 SECOND LETTER MOTION for Extension of Time to File Answer On consent re: 1 Complaint addressed to Magistrate Judge Katharine H. Parker from Simone Nicholso n dated May 6, 2022, FIRST LETTER MOTION to Adjourn Conference Jointly, On Consent addressed to Magistrate Judge Katharine H. Parker from Simone Nicholson dated May 6, 2022, FIRST LETTER MOTION for Extension of Time To Submit A Case Man agement Plan, Jointly, On Consent addressed to Magistrate Judge Katharine H. Parker from Simone Nicholson dated May 6, 2022. New York City Department of Education answer due 6/9/2022; granting 19 Letter Motion to Adjourn Conference; grantin g 19 Letter Motion for Extension of Time. APPLICATION GRANTED: Defendant's deadline to respond to the complaint is hereby extended toJune 9, 2022. The Case management plan will be due June 10, 2022. The Initial Case ManagementConference in th is matter that is scheduled for Tuesday, May 17, 2022 at 10:00 a.m. in Courtroom17D, 500 Pearl Street, New York, NY 10007 is hereby rescheduled to Friday, June 17, 2022 at 10:00a.m. ( Initial Conference set for 6/17/2022 at 10:00 AM before Magistrate Judge Katharine H. Parker.) (Signed by Magistrate Judge Katharine H. Parker on 5/8/2022) (va)
Case 1:22-cv-01200-JPO-KHP Document 20 Filed 05/08/22 Page 1 of 2
USDCSDNY
DOCUMENT
ELECTRONICALLY FILED
DOC#:._ _ _ _ _ __
DATE FILED:_ _ _ __
.05/08/2022
MEMO ENDORSED
THE CITY OF NEW YORK
HON. SYLVIA O. HINDS-RADIX
Corporation Counsel
LAW DEPARTMENT
100 CHURCH STREET
NEW YORK, NY 10007
W. Simone Nicholson
Special Assistant Corporation Counsel
Office: (212) 356-2394
Mobile: (646) 391-6899
May 6, 2022
VIA ECF
Hon. Katherine H. Parker
Daniel F. Moynihan
United States Courthouse
500 Pearl Street
New York, NY 10007
Re:
M.W., et. al. v. N.Y.C Dep’t of Educ., No. 22-cv-1200 (JPO)(KHP)
Dear Judge Parker:
I am Special Assistant Corporation Counsel in the office of Corporation Counsel, Sylvia O.
Hinds-Radix, attorney for Defendant in the matter referenced above, wherein Plaintiff seeks solely
attorneys’ fees, costs and expenses for legal work on an administrative hearing under the Individuals
with Disabilities Education Act 20 U.S.C. §1400, et. seq. (“IDEA”), as well as for this action.
I write to respectfully request a 30-day extension of time to respond to the complaint, from
May 9 to June 9, 2022. This is the second request for an extension and Plaintiff consents. Your
Honor granted the first request on March 8, 2022 (ECF 11). Further, the parties jointly request an
extension of time to submit a Proposed Case Management Plan (“CMP”) from May 10 to June 10,
2022, and an adjournment of the Initial Conference from May 17 to June 17, 2022.
The requested extension will give the parties time to engage in meaningful settlement
discussions that will hopefully lead to the resolution of this case without need for a conference or
motion practice. This office has successfully resolved many dozens of actions seeking solely IDEA
fees and costs with the Dayan Firm, and Defendant expects this case to follow that same course.
Accordingly, Defendant respectfully requests that the Court accept this submission and
extend Defendant’s deadline to respond to the complaint to June 9, 2022, extend the deadline for
submission of the CMP to June 10, 2022, and adjourn the Initial Conference to June 17, 2022
Case 1:22-cv-01200-JPO-KHP Document 20 Filed 05/08/22 Page 2 of 2
Thank you for considering these requests.
Respectfully submitted,
Simone Nicholson
/s/ W. Simone Nicholson
Special Assistant Corporation Counsel
cc:
Adam Dayan (via ECF)
APPLICATION GRANTED: Defendant's deadline to respond to the complaint is hereby extended to
June 9, 2022. The Case management plan will be due June 10, 2022. The Initial Case Management
Conference in this matter that is scheduled for Tuesday, May 17, 2022 at 10:00 a.m. in Courtroom
17D, 500 Pearl Street, New York, NY 10007 is hereby rescheduled to Friday, June 17, 2022 at 10:00
a.m.
05/08/2022
2
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