Smith v. Proguard Protection Inc. et al

Filing 22

ORDER granting 21 Letter Motion for Extension of Time to File. Application GRANTED. The parties' deadline to file a joint letter motion requesting the Court approve their settlement agreement in accordance with the Court's October 12, 2 023, order at Dkt. 20 is extended until Wednesday, December 13, 2023. The Court is highly unlikely to grant further extension requests absent extraordinarily good cause. If no letter or stipulation is filed by Wednesday, December 13, 2023, a confer ence shall be held on Friday, December 15, 2023, at 10:00 A.M. in Courtroom 443 of the Thurgood Marshall U.S. Courthouse, 40 Foley Square, New York, New York 10007. The conference scheduled for Friday, November 17, 2023 at 10:00 A.M. is CANCELED. P ursuant to Rule 2(C) of the Undersigned's Individual Practices, extension or adjournment requests must be made at least 48 business hours prior to the original due date absent an emergency. Counsel are admonished that any future extension or adjournment requests made in violation of the Undersigned's Individual Practices may be denied on that basis alone. SO ORDERED. (Signed by Judge Valerie E. Caproni on 11/13/2023) (tg)

USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
LEVIN-EPSTEIN & ASSOCIATES, P.C.
_____________________________________________________________________________________________
DOC #:
60 East 42nd Street • Suite 4700 • New York, New York 10165
DATE FILED: 11/13/2023

MEMO ENDORSED

T: 212.792-0048 • E: [e-mail]

November 13, 2023

VIA ECF
The Honorable Valerie E. Caproni, U.S.D.J.
U.S. District Court, Southern District of New York
40 Foley Square
New York, NY 10007
Re:

Smith v. Proguard Protection Inc. et al
Case No.: 1:23-cv-03694-VEC

Dear Honorable Judge Caproni:
This law firm represents Plaintiffs Aaron Smith, Tyishia Dudley, Colman Goncalvez,
Samuel Deadwyler (collectively, the “Plaintiff”) in the above-referenced matter.
Pursuant to Your Honor’s Individual Motion Practice Rules, this letter respectfully serves
to request an extension of time to comply with Your Honor’s October 12, 2023 Order [Dckt. No.
20], from November 12, 2023 to, through and including December 13, 2023.
This is the first request of its kind, and is made on consent of counsel for Defendants Robert
Hall, Richard Stanley and Proguard Protection Inc. (collectively, the “Defendants”).
The basis of this request is that the parties require additional time to finalize the necessary
paperwork to effectuate the dismissal of the instant action. The parties anticipate being in a position
to respond to Your Honor’s October 12, 2023 Order [Dckt. No. 20] on or before December 13,
2023.
Thank you, in advance, for your time and attention to this matter.
Respectfully submitted,
LEVIN-EPSTEIN & ASSOCIATES, P.C.
By: /s/ Jason Mizrahi
Jason Mizrahi, Esq.
60 East 42nd Street, Suite 4700
New York, New York 10165
Tel. No.: [phone]
Email: [e-mail]
Attorneys for Plaintiff
VIA ECF: All Counsel

1

Application GRANTED. The parties' deadline to file a joint letter motion requesting the Court approve
their settlement agreement in accordance with the Court's October 12, 2023, order at Dkt. 20 is
extended until Wednesday, December 13, 2023. The Court is highly unlikely to grant further
extension requests absent extraordinarily good cause.
If no letter or stipulation is filed by Wednesday, December 13, 2023, a conference shall be held on
Friday, December 15, 2023, at 10:00 A.M. in Courtroom 443 of the Thurgood Marshall U.S.
Courthouse, 40 Foley Square, New York, New York 10007.
The conference scheduled for Friday, November 17, 2023 at 10:00 A.M. is CANCELED.
Pursuant to Rule 2(C) of the Undersigned's Individual Practices, extension or adjournment requests
must be made at least 48 business hours prior to the original due date absent an emergency. Counsel are
admonished that any future extension or adjournment requests made in violation of the Undersigned's
Individual Practices may be denied on that basis alone.
SO ORDERED.

11/13/2023
HON. VALERIE CAPRONI
UNITED STATES DISTRICT JUDGE