Mecea v. NBCUniversal Media, LLC

Filing 11

ORDER granting #10 Letter Motion to Adjourn Conference. Application GRANTED. It is hereby ORDERED that Defendant shall enter an appearance and answer, move, or otherwise respond to the Complaint on or before September 27, 2024. It is further ORDERED that the September 3, 2024 Initial Pretrial Conference is ADJOURNED to Tuesday, October 22, 2024 at 9:30 a.m. in Courtroom 906 of the Thurgood Marshall Courthouse, New York, NY 10007. The parties are further ORDERED to to file on ECF a joint letter, as well as a proposed Civil Case Management Plan and Scheduling Order attached as an exhibit to the joint letter, no later than October 15, 2024. The parties shall use this Court's form proposed Civil Case Management Plan and Scheduling Order, which is available at https://nysd.uscourts.gov/hon-margaret-m-garnett. As Defendant has not yet entered an appearance, Plaintiff is directed to (1) to notify counsel for Defendant by serving upon them a copy of this Order and the Court's Individual Rules forthwith within three business days of the date of this Order (which service may occur electronically), and (2) to file proof of such notice with the Court within two business days of service. The Clerk of Court is respectfully directed to terminate Dkt. No. 10. SO ORDERED.. (Signed by Judge Margaret M. Garnett on 8/29/2024) Initial Conference set for 10/22/2024 at 09:30 AM in Courtroom 906, 40 Centre Street, New York, NY 10007 before Judge Margaret M. Garnett. (ks) Modified on 8/30/2024 (ks).

333 EARLE OVINGTON BOULEVARD, SUITE 402
UNIONDALE, NEW YORK 11553
T: 516-203-7600
F: 516-282-7878

August 28, 2024
August 29, 2024

Via ECF
Hon. Margaret M. Garnett
U.S. District Court
Southern District of New York
40 Foley Square, Room 2102
New York, NY 10007
Re:

Robert Mecea v. NBCUniversal Media, LLC
Case No: 1:24-cv-05233

Dear Judge Garnett:
We represent plaintiff Robert Mecea (“Plaintiff”) in the above-captioned matter and write pursuant
to Rule I(B)(5) of Your Honor’s Individual Rules to respectfully request an adjournment of the
September 3, 2024, Initial Pre-trial Conference and the associated filing deadline(s), and a 30-day
extension of time, to September 27, 2024, for defendant NBCUniversal Media, LLC
(“Defendant”), to file its appearance and respond to the Complaint.
1. Plaintiff, via counsel, attempted to contact Defendant in the hopes of Defendant appearing
in this action and in avoiding seeking entry of default against Defendant [see text entry
accompanying Dkt. No. 8]. In response thereto, counsel for Defendant contacted Plaintiff,
advising Plaintiff of their representation of Defendant.
2. In light of Defendant’s recent contact, Plaintiff respectfully requests a 30-day extension of
time, to September 27, 2024, for Defendant to file its appearance and respond to the
Complaint, and further requests that the Initial Pre-Trial Conference, currently scheduled
for September 4, 2024, at 9:30 a.m., along with the associated filing deadline(s) [Dkt. No.
7] 1, be adjourned for 30 days thereafter, to October 29, 2024, or to an alternative date
following the Defendant’s appearance in this matter.
3. Good cause exists for the instant request as counsel for Defendant has not yet filed an
appearance on this matter, and the adjournment and extension would permit the parties
time to competently discuss the required topics under Rule 26(f) and the most appropriate

Plaintiff acknowledges that the filing deadline for the Civil Case Management Plan and Scheduling Order as well
as the joint letter has past, and states that said missed deadline is the result of a clerical oversight with calendaring.
Counsel apologizes for the clerical oversight and subsequent oversight of the filing deadline and respectfully
submits that the Court’s Orders are taken very seriously.

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case management plan based on Defendant’s response to the Complaint. Further, the
additional time would enable the parties to discuss the possibility of early resolution.
4. This is Plaintiff’s first request for an adjournment and extension of time and the request is
made in good faith, not for the purposes of delay, and granting this request will not
prejudice any party in this matter.
Thank you for your consideration of this request.

Respectfully submitted,
SANDERS LAW GROUP
/s Jaymie Sabilia-Heffert
Jaymie Sabilia-Heffert
Application GRANTED. It is hereby ORDERED that Defendant shall enter an appearance and answer, move, or
otherwise respond to the Complaint on or before September 27, 2024. It is further ORDERED that the September
3, 2024 Initial Pretrial Conference is ADJOURNED to Tuesday, October 22, 2024 at 9:30 a.m. in Courtroom 906
of the Thurgood Marshall Courthouse, New York, NY 10007. The parties are further ORDERED to to file on ECF
a joint letter, as well as a proposed Civil Case Management Plan and Scheduling Order attached as an exhibit to the
joint letter, no later than October 15, 2024. The parties shall use this Court's form proposed Civil Case
Management Plan and Scheduling Order, which is available at https://nysd.uscourts.gov/hon-margaret-m-garnett.
As Defendant has not yet entered an appearance, Plaintiff is directed to (1) to notify counsel for Defendant by
serving upon them a copy of this Order and the Court's Individual Rules forthwith within three business days of the
date of this Order (which service may occur electronically), and (2) to file proof of such notice with the Court within
two business days of service.
The Clerk of Court is respectfully directed to terminate Dkt. No. 10.
SO ORDERED. Dated August 29, 2024.
HON. MARGARET M. GARNETT
UNITED STATES DISTRICT JUDGE