Elavon, Inc. v. Northeast Advance Technologies Inc. et al

Filing 597

ORDER granting 596 Letter Motion for Extension of Time to File. Granted. So Ordered. (Signed by Judge Kenneth M. Karas on 4/4/23) (yv)

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Case7:15-cv-07985-KMK
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Document 596
THE GINZBURG

~

LAW FIRM. P C

MEMORANDUM EN DORSED
Daniel Ginzburg
P: [phone]
F: [phone]
[e-mail]
Admitted co NJ and NY Bars

April 3, 2023
VIA ELECTRONIC FILING
Hon. Kenneth M. Karas, U.S.D.J.
Southern District of New York
The Hon. Charles L. Brieant Jr. Federal Building
300 Quarropas Street
White Plains, NY 10601-4150
Re:

Elavon, Inc. v. Northeast Advance Techs., Inc., et al
Civil Action No. 7:15-cv-7985-KMK-PED

Dear Judge Karas:
My firm represents plaintiff Elavon, Inc. in the above-referenced action. Fallowing up on
the Court's decision on the defendants' motions for summary judgment, I write to request that the
Court extend Elavon's time to move for reargument from April 13, 2023 , as required by Local
Civil Rule 6.3 , to May 5, 2023 .
Having reviewed the Court's decision on the summary judgment motions (ECF No . 595),
Elavon wishes to make a very limited motion for reargument on one or two discrete points.
However, I am leaving on a family vacation on April 5, 2023, and am due to file opposition to a
dispositive motion in the case of Stanislaw v. Thetford Township (E.D. Mich.) on that same date.
Therefore, I will be unable to file the motion for reargument before my departure.
I am returning to the office on April 17, 2023, but have a jury trial scheduled in the matter
of Pellegrino v. Century Pools (N.J. State Court) beginning on April 24, 2023, and which will
probably last that entire week. Therefore, I respectfully request the Court's leave to file the motion
for reargument by May 5, 2023. The Court may address the motion during the May 10, 2023
conference in this action.
On March 31 , 2023, I sought consent from opposing counsel for the relief requested herein.
However, I have not heard back from Messrs. Yurowitz and Landrigan as of this evening, and
wanted to file this motion before my departure.

The win1ab1i1r, 1.11w Firm, r,<;,
Mailin& Address
200 VILLAGE CENTER DRIVE, UNIT 7045
FREEHOLD, NEW JERSEY 07728

Case
597 Filed
Filed04/03/23
04/04/23 Page
Page2 2ofof2 2
Case7:15-cv-07985-KMK
7:15-cv-07985-KMK Document
Document 596
GINZBURG

THE

m1

LAW FIRM PC

My client and I thank the Court for its consideration of this matter.
Granted .

Respectfully submitted,

So Ordered.

Isl Daniel Ginzburg

Daniel Ginzburg

4/4/23

Cc:

All Counsel of Record (via ECF)

The uinzburx 1.1w Firm, r,<;,
Mailing Address
200 VILLAGE CENTER DRIVE, UNIT 7045
FREEHOLD, NEW JERSEY 07728