Potapova v. Toyota Motor Credit Corporation
Filing
81
ORDER granting 80 Letter Motion for Extension of Time to File Application GRANTED. The Clerk of Court is directed to terminate ECF No. 80. SO ORDERED. (Signed by Judge Jesse M. Furman on 1/29/2025) (ar)
DAFNEY DUBUISSON STOKES
Member of NJ, PA, NY, OH and AK Bars
dstokes@wongfleming.com
January 28, 2025
VIA ECF
Hon. Jesse M. Furman
U.S. District Judge
U.S. District Court – S.D.N.Y.
40 Foley Square
Brooklyn, NY 11201
Re:
Iuliia Potapova v. Toyota Motor Credit Corporation
Docket No. 1:23-cv-00571-JMF
Dear Judge Furman,
We represent Toyota Motor Credit Corporation (“Defendant”) in the above-referenced
action. We write jointly with Plaintiff Iuliia Potapova (“Plaintiff”) (together, the “Parties”) pursuant
to Section 6.F of Your Honor’s Individual Rules and Practices in Civil Cases, requesting that the
Court enlarge the deadline by which the Parties are to respond to the opponent’s motions in limine.
(ECFs 66, 67.) Those Motions were filed January 16, 2025, and by the Court’s Practices, responses
were originally due January 23, 2025. FURMAN INDIV. PRACTICES § 6.F.i. A previous six-day
enlargement was granted by Your Honor on January 26, 2025, making the response briefs due
January 29, 2025. (ECF 76). The Parties would respectfully request that the Court grant an additional
six-day enlargement, making the response briefs due February 4, 2025. Because good cause exists
to enlarge the deadline, the Court should grant the Motion.
Yesterday, Defendant’s counsel experienced a catastrophic computer glitch or error which
led to the deletion of responsive materials. Defendant’s counsel has been working diligently to
recreate the lost documents and requests additional time to in order to repair its lost documentation
completing its responses to Plaintiff’s motions in limine. Plaintiff’s counsel has consented to this
request, and we therefore jointly request that the Court grant the Motion and enlarge the deadline.
This is the Parties’ second request to enlarge the deadline by which they are to respond to
motions in limine. This request is not made for reasons of delay or other purpose, and this request
will not impact any other deadlines in the case as the trial date has been set for May 6, 2025. The
Parties do not anticipate further requests for an extension.
Based on the foregoing, the Parties therefore request that the Court grant this Motion and
enlarge the Parties’ deadline to file their responses to motions in limine to Wednesday, February 4,
2025.
821 ALEXANDER ROAD, SUITE 200 ? P.O. BOX 3663 ? PRINCETON, NJ 08543-3663
TEL: (609) 951-9520 ? FAX: (609) 951-0270
WWW.WONGFLEMING.COM
CALIFORNIA ? DISTRICT OF COLUMBIA ? FLORIDA ? GEORGIA ? IDAHO ? INDIANA ? MARYLAND
MICHIGAN ? NEVADA ? NEW JERSEY ? NEW YORK ? OREGON ? PENNSYLVANIA ? TEXAS ? WASHINGTON
ATTORNEYS ADMITTED SOLELY IN THE JURISDICTION WHERE LISTED OFFICE IS LOCATED, UNLESS OTHERWISE NOTED
Thank you for your consideration. If you have any questions, please do not hesitate to contact
our office.
Respectfully submitted,
WONG FLEMING
/s/ Dafney Dubuisson Stokes
Dafney Dubuisson Stokes
Counsel for Defendant
/s/ Craig C. Marchiando
Craig C. Marchiando
Counsel for Plaintiff
Application GRANTED. The Clerk of Court is directed to terminate ECF No. 80.
SO ORDERED.
January 29, 2025
2
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?