Sanchez v. BTO America Limited

Filing 28

ORDER granting 27 Letter Motion for Extension of Time( Motions due by 10/16/2022.); granting 27 Letter Motion for Extension of Time to File. Application GRANTED. Defendant shall file its motion to dismiss by October 16, 2022. Plaintiff shall f ile an opposition by November 7, 2022. Defendant shall file a reply by November 14, 2022. The parties shall comply with the Court's Individual Rules in filing their motions and supporting papers. (Signed by Judge Lorna G. Schofield on 9/19/22) (yv)

Case 1:22-cv-02419-LGS Document 28 Filed 09/19/22 Page 1 of 2

LAW OFFICES OF MITCHELL S. SEGAL, P.C.
1010 NORTHERN BOULEVARD
N.Y.C. Office
SUITE 208
137 Fifth Avenue, 9th Floor
GREAT NECK, NEW YORK 11021
New York, N.Y. 10010
Ph: [phone]
Ph: [phone]
Fx: [phone]
Via ECF Filing
Honorable Lorna G. Schofield
U.S. District Court – SDNY
500 Pearl Street
New York, New York 10007

September 16, 2022
Application GRANTED. Defendant shall file its motion
to dismiss by October 16, 2022. Plaintiff shall file an
opposition by November 7, 2022. Defendant shall file
a reply by November 14, 2022. The parties shall
Re: Cristian Sanchez v. BTO America Limited comply with the Court's Individual Rules in filing their
motions and supporting papers.
Case No.: 1:22-cv-02419-LGS

Dear Judge Lorna G. Schofield:

Dated: September 19, 2022
New York, New York
Pursuant to your Honor’s Order dated July 27, 2022, the Defendant BTO America Limited
was required to file its motion to dismiss the above referenced action pursuant to Fed. R. Civ. P.
12(b)(1) and 12(b)(6) on or before September 16, 2022. As stated in the previously filed joint
letter, I have been unable to reach my client and have had no any communication for weeks. I
have found out that the principal lives in Australia and the associate that was communicating
with me was terminated from the Company. I have sent numerous emails and made calls but to
date I have not heard back. As such I cordially request an extension of 30 days to file the
motion. (I am out of the country for 7 days during this time). Additionally, Plaintiff’s counsel
and I have had settlement discussions but I have been unable to communicate those with my
client. As such I cordially request to extend the briefing schedule as follows.
1. Defendants motion to be filed on or before October 16, 2022
2. Plaintiff’s opposition to be filed on or before November 7, 2022.
3. Defendants reply to be filed on or before November 14, 2022.
Plaintiff’s counsel has consented to this extension request. I apologize for this late notice
as I was hoping and waiting for my client to respond to my messages. I thank this honorable
Court for its review of this request.

Respectfully submitted,
/s/ Mitchell Segal

Case 1:22-cv-02419-LGS Document 28 Filed 09/19/22 Page 2 of 2

By ECF
Cc: All counsel of record

______________________
Mitchell Segal