Steinberg v. Cushman & Wakefield, Inc. et al

Filing 29

ORDER granting 27 Letter Motion to Adjourn Conference. Application to adjourn the initial pretrial conference is GRANTED. Decision on rescheduling the conference is REFERRED to the magistrate judge assigned to this matter. SO ORDERED.. (Signed by Judge Dale E. Ho on 10/24/2024) (ks)

Application to adjourn the initial pretrial conference is GRANTED.
Decision on rescheduling the conference is REFERRED to the
magistrate judge assigned to this matter. SO ORDERED.

Attorneys at Law

Johner Taylor (JT) Wilson III
t 312.499.1435
f 312.845.1998
[e-mail]

Date: October 24, 2024
New York, New York

Dale E. Ho
United States District Judge

October 23, 2024
VIA ECF
Hon. Dale E. Ho, U.S.D.J.
United States District Court, Southern District of New York
Thurgood Marshall Courthouse
40 Foley Square, Courtroom 905
New York, New York 10007
Re:

Ahouva Steinberg v. Cushman & Wakefield, Inc., et al.
Case No. 1:24-cv-06470
Certain Defendants’ Letter Motion to Adjourn

Dear Judge Ho:
The undersigned counsel represents Defendants Cushman & Wakefield, Inc., Cushman &
Wakefield 1, Inc., Cushman & Wakefield Capital Services, LLC (collectively, the “C&W
Entities”), and Pinnacle Property Management Services, LLC (“PPMS”) in the above-referenced
matter. Pursuant to Your Honor’s Individual Rules and Practices Paragraph 2(e), we write to
respectfully request an adjournment of the Initial Conference, which is currently scheduled for
October 31, 2024, and the accompanying deadlines as set forth in Federal Rule of Civil Procedure
26(f) and the Notice of Initial Pretrial Conference issued by this Court on August 29, 2024 (ECF
No. 17).
PPMS and the C&W Entities request this adjournment because the deadline to answer,
move, or otherwise respond to the Complaint is October 29, 2024, and anticipate filing a pleading
other than an answer that will dispose of the Complaint against certain Defendants entirely. As a
result, PPMS and the C&W Entities seek to adjourn the existing deadlines to initiate and
meaningfully engage in the discovery process after their respective responses to the Complaint
have been finalized and filed. Counsel for Defendants Cappelli Development, LLC, Cappelli
Organization, LLC, and RFMCH Huguenot Property Owner, LLC (the “Cappelli Defendants”)
consent to this request. Counsel for Plaintiff Ahouva Steinberg (“Plaintiff”) does not consent to
this request as she does not believe the adjournment is necessary.
The following alternate conference dates are mutually agreeable to the C&W Entities,
PPMS, the Cappelli Defendants, and Plaintiff: December 18, 2024, and December 19, 2024. Also,
all Defendants are agreeable to proceed on December 23, 2024, and Plaintiff’s counsel of record
might be able to attend an Initial Conference if set for December 23, 2024.
Epstein Becker & Green, P.C. | 227 W. Monroe Street, Suite 4500 | Chicago, IL 60606 | t 312.499.1400 | f 312.845.1998 | ebglaw.com

Hon. Dale E. Ho, U.S.D.J.
October 23, 2024
Page 2

This is the first request for an adjournment of the Initial Conference. The parties do not
have another scheduled appearance before the Court.
Thank you for your consideration of our submission.
Respectfully submitted,
/s/ Johner T. Wilson III
Johner T. (.J.T.) Wilson III