Morgan v. Champagne Campaign, Inc.

Filing 8

ORDER granting 7 Letter Motion for Extension of Time to Answer re 7 CONSENT LETTER MOTION for Extension of Time to File Answer re: 1 Complaint or Otherwise Respond addressed to Judge Lorna G. Schofield from Sean J. Kirby dated July 5, 2024.CONSENT LETTER MOTION to Adjourn Conference Currently Scheduled for July 17, 2024 addressed to Judge Lorna G. Schofield from Sean J. Kirby dated July 5, 2024., 1 Complaint ; granting 7 Letter Motion to Adjourn Conference. Application GRANTED. Defendant shall answer or otherwise respond to the Complaint by August 9, 2024. The initial pretrial conference scheduled for July 17, 2024, is adjourned to August 14, 2024, at 4:00 P.M. At that time, the parties shall call 888- 363-4749 and enter the access code 558-3333. The deadline for the parties to file the joint letter and proposed case management plan is extended to August 7, 2024. Champagne Campaign, Inc. answer due 8/9/2024( Initial Conference set for 8/14/2024 at 04:00 PM before Judge Lorna G. Schofield.) (Signed by Judge Lorna G. Schofield on 7/8/2024) (sgz)

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July 5, 2024 VIA ECF AND EMAIL Honorable Lorna G. Schofield United States District Judge United States District Court Southern District of New York 40 Foley Square New York, New York 10007 Re: Application GRANTED. Defendant shall answer or otherwise respond to the Complaint by August 9, 2024. The initial pretrial conference scheduled for July 17, 2024, is adjourned to August 14, 2024, at 4:00 P.M. At that time, the parties shall call 888-363-4749 and enter the access code 558-3333. The deadline for the parties to file the joint letter and proposed case management plan is extended to August 7, 2024. Dated: July 8, 2024 New York, New York Morgan v. Champagne Campaign, Inc., Civil Action No. 1:24-cv-04127 (LGS) Dear Judge Schofield: We represent defendant Champagne Campaign, Inc. (“Defendant”) in connection with the above-referenced matter. Defendant was served with the summons and complaint on June 18, 2024, and its response is currently due July 9, 2024. As we have only recently been retained and require more time to investigate the claims and prepare Defendant’s response, we reached out to Plaintiff’s counsel, Dan Shaked, Esq., who agreed to extend Defendant’s time to respond to the complaint for an additional thirty days. Accordingly, we write with Plaintiff’s consent to request a brief extension of time for Defendant to answer, move or otherwise respond to the complaint, until August 9, 2024. Pursuant to You Honor’s Individual Rules, Defendant states that there have been no previous requests for an extension. As there is also an initial scheduling conference before Your Honor scheduled for July 17, 2024, the parties also agreed that it would be more efficient to hold the conference after Defendant has responded to the complaint. Accordingly, the parties jointly request that the initial conference be adjourned until a date and time after August 9, 2024 that is convenient for the Court. Please feel free to contact me if Your Honor desires any additional information. Respectfully submitted, /s/ Sean J. Kirby Sean J. Kirby cc: Dan Shaked, Esq. (via ECF)

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