Conklin v. Specialist, L.L.C. et al

Filing 139

ORDER granting [522 in 16-cv-4643-KMK-PED] CONSENT LETTER MOTION for Extension of Time Concerning Solely Weeks' Medical Expert Report. Granted. SO ORDERED. (Signed by Judge Kenneth M. Karas on 12/4/2019) (jca)

Cas.cv-04643-KMK-PED Document 522 Filed 12/03/19 Page 1 of 2
New Jersey 151 Bodman Place, Suite 200, Red Bank, NJ 07701
Telephone: [phone] Te lefax: 732,530 ,9536

BETANCOURT
VAN HEMMEN
GRECO&
K ENYONu.c

New York 75 South Broadway - 4 th Floor, Wh ite Plai ns, NY 10601
Telephone: [phone] Telefax: 914.997.1101

December 3,

2019MEMQ ENDORSED

ByECF
Hon. Kenneth M. Karas, U.S.D.J.
United States District Court
Southern District of New York
300 Quarropas Street
White Plains, New York 10601-4150
Re:

In re Specialist and Other Vessel Owner Limitation Actions
Lead Docket No.: 16-cv-4643 (KMK)
Related Nos.: 16-cv-2515, 16-cv-3353, 16-cv-3579, 16-cv-5010, 16-cv-7001

Dear Judge Karas:
We represent Weeks Marine, Inc. ("Weeks") in these cases. Weeks has retained
Dr. Jeffrey G. Odel to provide medical expert testimony concerning the medical history and
vision of New York Marine Towing' s mate on watch on the tug SPECIALIST, Paul Amon.
Dr. Odel has advised that it is not possible for him to produce his report by December 15,
2019, the date recently set by the Court for service of expert reports. He advised that his
hospital, Columbia University Medical Center, just changed their medical record software
and that he is responsible for both learning the system as well as fulfilling his department's
obligations regarding the change, which will require his immediate and prolonged
attention. This, coupled with the holidays, creates his scheduling issues. Dr. Odel has
advised that he will be able to produce his report by January 10, 2020. Accordingly, we
respectfully request the Court grant an extension with respect to the service of Dr. Odel' s
report and corresponding rebuttal reports, if any, as follows:
January 10, 2020
March 15, 2020

Deadline to serve Dr. Odel's expert report; and
Deadline to serve rebuttal expert reports with respect to Dr.
Odel' s report.

www.bvgklaw.com

Case 7:16-cv-04643-KMK-PED Document 522

Filed 12/03/19 Page 2 of 2

No other dates set forth in Your Honor's November 25, 2019 Order are impacted.
(D.E.521). WehavespokenwithcounselforAmon'semployer,NewYorkMarineTowing,
and he has consented to our request, as have counsel for all other parties.
Respectfully submitted,
BETANCOURT, VAN HEMMEN, GRECO

By

s/ Ronald Betancourt

RB/jc
cc

All counsel entered in this case via ECF.

-2-

& KENYON LLC