Dyson, Inc. v. Kuehne Nagel, Inc. et al

Filing 29

ORDER granting #26 Letter Motion to Adjourn Conference. The conference is adjourned to December 8, '23 at 12 noon and must be attended in person or by proxy (who must be fully authorized to make commitments. So Ordered. (Initial Conference set for 12/8/2023 at 12:00 PM before Judge Louis L. Stanton.) (Signed by Judge Louis L. Stanton on 11/15/23) (yv)

Andrew R. Spector, Partner
Admitted in Florida, New York and Texas

SPECTOR RUBIN
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November 14, 2023

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Honorable Louis L\itanton
United States District Judge
United States District Court
Southern District of New York
500 Pearl Street
New York, New York 10007
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Dyson, Inc. v. Kuehne+ Nagel Inc. d/b/a Blue"t.~r
L\ne v. MSC ll....~~-yed,
Mediterranean Shipping Company S.A.
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Southern District of New York Case No. 1:23-cv-08684-LLS .,\--1> wt"1KL ~ "1-wL.. { ·i,n«,.J~

Dear Judge Stanton,

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The undersigned represents Defendant/Third-Party Plaintiff, Kuehne + Nagel Inc. d/b/JCJ\Aiv:5 ·
Blue Anchor America Line ("K+N") in the above-captioned matter. The foregoing is submitted
pursuant to Your Honor's Individual Practices and is submitted with the consent of all Parties. The
case is currently set for an Initial Pre-Trial Conference on November 17, 2023, at 2:30 p.m. (ECF , \ ( \,; / 2 '3 I
20).

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The undersigned counsel for K+N respectfully submits that he has other litigation matters
scheduled on Friday November 17, 2023, and will be out of this jurisdiction. Further, another
attorney at the undersigned law firm on this matter (Troy H. Geisser) who otherwise could have
covered is unavailable on Friday, November 17, 2023. Accordingly, the undersigned counsel
respectfully requests that this Court allow the undersigned counsel to appear telephonically at the
Initial Pre-Trial Conference on November 17, 2023, at 2:30 p.m.
Further, the undersigned counsel respectfully submits that counsel for Third-Party
Defendant, MSC Mediterranean Shipping Company S.A. ("MSC") has recently reached out to
counsel for K+N and that MSC has not yet appeared in the instant action. As such, in the alternate,
the undersigned counsel respectfully requests that this Court grant an adjournment of the Initial
Pre-Trial Conference on November 17, 2023, at 2:30 p.m. We note that this is the Parties' first
request for an adjournment of the Conference.
The undersigned counsel has conferred with respective counsel for Plaintiff, Dyson, Inc.
("Dyson"), and Third-Party Defendant, MSC, and both Parties consent to the requested relief;
however, we note that counsel for MSC is unavailable on Friday for the Conference and will be
submitting its own request for relief.

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3250 Mary Street, Suite 405, Miami, Florida 33133
11 Broadway, Suite 615, New York, New York 10004
www.spectorrubin.com

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The Honorable Louis L. Stanton
United States District Judge
November 14, 2023
Page 2
We appreciate Your Honor's consideration of this request for an accommodation to allow
for remote appearance and/or an adjournment of the Initial Pre-Trial Conference. Thank you.
Respectfully submitted,
SPECTOR RUBIN, P .A.

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Andrew R. Spector
cc:

All Counsel of Record (via ECF)

3250 Mary Street, Suite 405, Miami, Florida 33133
11 Broadway, Suite 615, New York, New York 10004
www.spectorrubin.com