Gamble v. Cort et al

Filing 49

ORDER granting 48 Letter Motion to Adjourn Conference. APPLICATION GRANTED: The Case Management Conference in this matter scheduled for Wednesday, June 12, 2024 at 2:00 p.m. in Courtroom 17-D, United States Courthouse, 500 Pearl Street, New Yor k, New York is hereby rescheduled to Monday, August 5, 2024 at 10:30 a.m. The Clerk of Court is directed to mail a copy of this endorsement to the Plaintiff. Case Management Conference set for 8/5/2024 at 10:30 AM in Courtroom 17D, 500 Pearl Street, New York, NY 10007 before Magistrate Judge Katharine H. Parker. (Signed by Magistrate Judge Katharine H. Parker on 6/4/2024) (vfr)

Case 1:23-cv-06443-LGS-KHP Document 48 Filed 06/04/24 Page 1 of 2

THE CITY OF NEW YORK

MURIEL GOODE-TRUFFANT
Acting Corporation Counsel

BY ECF
Honorable Katharine H. Parker
United States Magistrate Judge
United States District Court
Southern District of New York
500 Pearl Street
New York, New York 10007

LAW DEPARTMENT
100 CHURCH STREET
NEW YORK, NY 10007

ELISSA JACOBS
Senior Counsel
Phone: [phone]
Fax: [phone]
Email: [e-mail]

June 4, 2024
APPLICATION GRANTED: The Case Management Conference in
this matter scheduled for Wednesday, June 12, 2024 at 2:00 p.m. in
Courtroom 17-D, United States Courthouse, 500 Pearl Street, New
York, New York is hereby rescheduled to Monday, August 5, 2024
at 10:30 a.m. The Clerk of Court is directed to mail a copy of this
endorsement to the Plaintiff.

Re: Gamble v. Assistant Commissioner Antoinette Cort and Captain Erica
Dixon.
23-CV-6443 (LGS)

06/04/2024

Your Honor:
I am a Senior Counsel in the Office of Muriel Goode-Truffant, Acting
Corporation Counsel of the City of New York, and the attorney for Defendants Assistant
Commissioner Antoinette Cort and Captain Erica Dixon in the above-referenced case. 1 I write
on behalf of defendants to respectfully request that the Court adjourn the Case Management
Conference currently scheduled for June 12, 2024 at 2:00 pm to June 19, 2024. This is
Defendants’ first request for an adjournment. Plaintiff consents to the instant request.
By way of background, defendants have been attempting to obtain discovery from
plaintiff since January 24, 2024. As plaintiff has yet to provide the requested discovery,
defendants moved to compel the discovery on May 21, 2024. (ECF No. 44) On May 23, 2024,
the Court referred this matter to Your Honor for general pretrial supervision. (ECF No. 46). On
May 28, 2024, Your Honor scheduled a Case Management Conference for June 12, 2024, at 2:00
pm. (ECF No. 47).

This case has been assigned to Assistant Corporation Counsel Jessica Ochoa. Ms. Ochoa is a member in good
standing with the New York State Bar (No. 6124655) as well as admitted to practice before the U.S. District Courts
of the District of Columbia (No. 1736588) and Maryland (No. 30564). She is currently in the process of being
admitted to practice before the present court. Ms. Ochoa may be reached directly at [phone].

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Case 1:23-cv-06443-LGS-KHP Document 48 Filed 06/04/24 Page 2 of 2

On June 3, 2024, Defendants’ counsel called Plaintiff to discuss the status of
discovery and to obtain consent for this extension request. Plaintiff consented to the request and
agreed to sign and provide the necessary releases for Defendants to obtain documents relevant to
his claims as well as answer Defendants’ discovery requests. 2
At this time, Defendants
respectfully request an adjournment of the Case Management Conference as counsel will be
unavailable on June 12, 2024, at 2:00 pm. Additionally, Plaintiff has indicated that due to his
work schedule, a morning conference time would allow him to attend a conference with minimal
impact on his employment. Finally, Defendants respectfully request an extension of discovery in
light of the above as discovery is currently set to close on June 12, 2024.
Accordingly, Defendants respectfully request that the Court adjourn the
scheduling conference on June 12, 2024 to June 19, 2024, preferably in the morning to
accommodate Plaintiff’s work schedule.
Defendants thank the Court for its time and consideration of these requests.
Respectfully submitted,
/s/_Elissa Jacobs_______________
Elissa Jacobs
Senior Counsel
Special Federal Litigation Division

cc:

BY MAIL
Kevin Gamble
Plaintiff Pro Se
1995 Adam Clayton Powell Jr. Boulevard
New York, New York 10026
[phone]
[e-mail]

While Plaintiff did agree to provide Defendants with discovery, at the time of filing, Defendants have not received
the necessary releases or discovery.

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