Alves v. Affiliated Care of Putnam, Inc. et al

Filing 343

ORDER granting 342 Letter Motion for Extension of Time to File. Granted. So Ordered. (Signed by Judge Kenneth M. Karas on 12/28/2023) (tg)

Case 7:16-cv-01593-KMK Document 342 Filed 12/28/23 Page 1 of 1

Charny & Wheeler P.C.
Attorneys at Law
42 West Market Street
Rh inebeck, NY 12572
Tel: [phone]
Fax: [phone]

Nathaniel K. Charny(NY &NJ Borl
nchorny@c hornywheeler.com

Russell G. Wheeler
rwh eeler@ chornywheeler.com

H. Joseph Cronen
jcronen@ chornywheeler ..co m

December 28, 2023
ByECF
Hon. Kenneth M. Karas, U.S.D.J.
The Hon. Charles L. Brieant Jr.
Federal Building & Courthouse
Southern District of New York
300 Quarropas Street
White Plains, New York 10601-415 0
Re :

Maria Alves, et al. v. Affiliated Home Care of Putnam, Inc., et al.
Civil Action No. 7:16-cv-1593 (KMK)

Dear Judge Karas,
This office is co-counsel to Plaintiff's in the above-referenced matter. Currently due tomorrow is
the parties' proposed Joint Pretrial Order. In addition, Defendants have filed a motion styled
"Motion to Decertify Collective Action and Class Action," which per Your Honor's Individual
Rules would require opposition on or before January 2, 2024.
I write on consent of all counsel to adjust the calendar so both of these submissions are due on
January 23 , 2024.
The reasons for this request are both of these deadlines have snuck up on counsel, the holidays,
my service as counsel to the United Auto Workers which has preoccupied my time, my cocounsel's movement to a new firm, Defendants securing successor counsel, and the vagaries of
our busy calendars.
Of course, if Your Honor intends to schedule the trial on this matter in a more immediate
fashion, we understand that you will adjust this request accordingly.

Thank you for your attention to this request.
Granted.

~d'J!/r'.~
12/28/23

cc:

Daniel Stafford, Esq. (by ECF)
Daniel S. Bretzius, Esq. (by ECF)

Respectfully Submitted:

~l~