Reclaim the Records et al v. United States Department of State

Filing 49

ORDER granting 48 Letter Motion for Extension of Time to File. Application GRANTED. Plaintiffs' reply brief is due August 2, 2024. No further extensions will be granted absent extraordinarily good cause. SO ORDERED. (Signed by Judge Valerie E. Caproni on 7/3/2024) (ks)

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Case 1:23-cv-01529-VEC Document 48 Filed 07/03/24 Page 1 of 2 July 3, 2024 828900.09400 MEMO ENDORSED BY ECF The Honorable Valerie E. Caproni United States District Court Southern District of New York Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007 Re: (212) 277-5825 drankin@blhny.com USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 07/03/2024 Reclaim the Records and Alec Ferretti v. United States Department of State, No. 23 Civ. 1529 (VEC) Your Honor: I am a partner at Beldock Levine & Hoffman LLP. Mr. Benjamin Meyers, the author of the Plaintiffs’ papers, was just released from Bellevue Hospital on Monday night. On June 24th he went for an examination at Gouverneur Hospital because his shortness of breath was getting worse. They performed tests and determined that Mr. Meyers needed to be in the care of a cardiologist immediately. He was then transferred to Bellevue where he remained for the last week. Mr. Meyers long term prognosis is good, but as he was just released from the Hospital, it is likely to take a couple of weeks for him to be back to full strength. We respectfully request a 30-day extension of time reply to the Government’s opposition to our cross-summary judgment motion. The Government consents to this request. This will allow Mr. Meyers to complete the briefing on this matter, or if he is unable, for another attorney to get up to speed and complete the briefing. We apologize for the inconvenience this causes to the Court and the parties. Should this request be granted, the plaintiffs’ reply would be filed by August 2, 2024. Presently, the reply is due today, July 3, 2024. Case 1:23-cv-01529-VEC Document 48 Filed 07/03/24 Page 2 of 2 The Honorable Valerie E. Caproni July 3, 2024 Page 2 We thank the Court for its attention to this matter. Respectfully submitted, David B. Rankin Application GRANTED. Plaintiffs' reply brief is due August 2, 2024. No further extensions will be granted absent extraordinarily good cause. SO ORDERED. 07/03/2024 HON. VALERIE CAPRONI UNITED STATES DISTRICT JUDGE

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