Jimenez v. City of New York et al

Filing 44

ORDER granting 43 Letter Motion for Extension of Time to File. Application granted. So ordered. (Signed by Judge Naomi Reice Buchwald on 2/7/2024) (va)

THE CITY OF NEW YORK

HON. SYLVIA O. HINDS-RADIX
Corporation Counsel

LAW DEPARTMENT

MARK D. ZUCKERMAN
Senior Counsel
E-mail: [e-mail]
Phone: [phone]
Fax: [phone]

100 CHURCH STREET
NEW YORK, NY 10007

February 6, 2024
VIA ECF
The Honorable Naomi Reice Buchwald
United States District Judge
Southern District of New York
500 Pearl St.
New York, NY 10007
Re: Ricardo Jiminez v. City of New York, et. al., 23 Civ. 6751 (NRB)
Your Honor:
I am a Senior Counsel in the office of the Hon. Sylvia O. Hinds-Radix,
Corporation Counsel of the City of New York, representing defendants City of New York, Bronx
County DA’s Office, Wendell Stradford, Christopher Horn and Karen Serrano-Paglia, “as
Administrator of the Estate of Michael Serrano” in the above-referenced matter. At Docket 35,
on January 22, 2024, plaintiff filed a second amended complaint, and substituted Karen SerranoPaglia, “as Administrator of the Estate of Michael Serrano” for the deceased Michael Serrano.
Earlier, today, at Docket 42, I appeared as counsel of record for Karen Serrano-Paglia, “as
Administrator of the Estate of Michael Serrano.” We previously filed notices of appearance on
behalf of the other defendants. In the interest of judicial economy, we propose to file one
combined motion to dismiss on behalf of all defendants. Counsel have conferred and, on
consent, propose the following amended briefing schedule: 1) defendants’ motion to dismissMarch 1, 2024; 2) plaintiff’s response-April 6, 2024; and 3) defendants’ reply-April 20, 2024.
This is the first such request for an extension of the briefing schedule on
defendants’ motion to dismiss.
Application granted.
So ordered.
Dated:

February 7, 2024
New York, New York

Thank you for your consideration herein.
Respectfully submitted,
/s/ Mark D. Zuckerman
Mark D. Zuckerman
Senior Counsel

cc:

All Counsel (via ECF)

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