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)

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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

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