Adams v. Annucci

Filing 104

MEMO ENDORSEMENT granting 103 Letter Motion for Extension of Time to Complete Discovery; granting 103 Letter Motion to Adjourn Conference. ENDORSEMENT: Granted, but there will be NO more extensions. The conference is adjourned to 12/14/21, at 10:00 a.m. Defense counsel is to mail a copy of this memo endorsement to Plaintiff and certify this was done in a filing by 10/14/21. SO ORDERED. ( Deposition due by 11/16/2021.)( Case Management Conference set for 12/14/2021 at 10:00 AM before Judge Kenneth M. Karas.). (Signed by Judge Kenneth M. Karas on 10/9/2021) (tg)

Case 7:17-cv-03794-KMK-JCM

Document 103 Filed 10/08/21 Page 1 of 2

MEMO ENDORSED
STATE OF NEW YORK
OFFICE OF THE ATTORNEY GENERAL
LETITIA JAMES

DIVISION OF STATE COUNSEL

ATTORNEY GENERAL

LITIGATION BUREAU

October 8, 2021

VIAECF
Hon. Kenneth M. Karas
United States District Court
Southern District of New York
300 Quarropas Street
White Plains, NY 10601
Re:

Adams v. Annucci, 17-CV-3794 {KMK){JCM)

Dear Judge Karas:
This Office represents Defendants Anthony Annucci and Ann Marie Sullivan
("Defendants') in the above-referenced action. I write the Court respectfully seeking to adjourn
the conference scheduled for October 12, 2021 as well as an extension of the fact discovery
deadlines. I attempted to contact the Plaintiff to discuss this application but was unable to reach
him.
Fact Depositions are scheduled to be completed by October 16, 2021. Due to the terms of
Plaintiff's parole conditions as a registered sex offender, and the need to conduct this deposition
virtually, the undersigned has been coordinating with the Plaintiff and his Parole Officer to be able
to appear for the same. As such, additional time will be needed to schedule the deposition. As such,
a thirty (30) day extension of all deadlines is needed. This is the fourth request for an extension of
the deposition deadline and the third request for an extension of all fact discovery deadlines in this
case.

If amenable to the Court it is respectfully requested that the deadlines be extended to the
following:
A) All Fact Discovery: from November 3, 2021 to December 3, 2021
B) Fact Depositions: from October 16, 2021 to November 16, 2021

Case 7:17-cv-03794-KMK-JCM Document 103 Filed 10/08/21 Page 2 of 2

Page2
We sincerely appreciate the Court's time and thank you for your consideration of this
application.
Granted, but there will be NO more extensions. The
Defense
conference is adjourned to 12/ lq /21, at
counsel is to mail a copy of this memo endorsement to
Plaintiff and certify this was done in a filing by 10/14/21.

lo :oo

Respectfully submitted,

SI Julie A. Ortiz
Julie A. Ortiz (JR1817)
Assistant Attorney General
28 Liberty Street, 18th Floor
New York, NY 10005
[phone]
Julie. [e-mail]

cc:

Jerry Adams (by regular mail)
PO Box 663
Glen Wild, NY 12738