Walker v. Odell et al

Filing 63

ORDER granting 62 Letter Motion for Extension of Time to File. Application granted. SO ORDERED. (Signed by Judge Philip M. Halpern on 11/19/2020) (ks)

Case 7:17-cv-08120-PMH Document in Filed 11/19/20 Page Page
Case 7-17-cv-08120 Document 62 Filed 63 NYSD on 11/18/2020 1 of 1 1 of 1

David M. Hazan, Esq.
30 Vesey Street, 4h Floor
New York, New York 10007
Phone: [phone]
Fax: [phone]
[e-mail]

November 18, 2020

VIA ECF
Honorable Philip M. Halpern
United State District Judge, SDNY
Daniel Patrick Moynihan
United States Courthouse
500 Pearl Street
New York, New York 10007
Re: Florence Walker v. Dr. Crossley O’Dell, 17 Civ. 8120 (PMH)
Your Honor:
I represent the plaintiff Florence Walker in the above-referenced matter. I write jointly
on behalf of all parties to respectfully request a short enlargement of time, from November 18,
2020 to November 23, 2020 for the parties to file their proposed voir dire questions, joint jury
charge, and a joint verdict form in compliance with Rule 6(B) of the Court’s Individual
Practices. Pursuant to the Court’s Individual Practices, the parties are trying to reach an
agreement regarding the language and content that will be included in each of the documents due
to be filed with the Court, and the parties have made significant progress in that regard. As the
Court may recall, earlier this week plaintiff requested a two day enlargement of time to file these
documents because upon receiving defendant’s proposed jury charge Upon review of certain
portions of defendant’s proposed jury charge, it became necessary for counsel for plaintiff to
conduct additional research about whether portions of defendant’s proposed charge were legally
correct. Counsel for plaintiff has since completed the necessary research and based, in part, on
the research proposed extensive amendments to defendant’s proposed jury charge. Defense
counsel was not provided with the proposed amendments until after noon today. Consequently,
defense counsel requires an opportunity to review the proposed amendments and meet and
confer with counsel for plaintiff to see whether the parties reach an agreement about what should
be contained in a jointly proposed jury charge. For these reasons, the parties respectfully request
that the Court grant the parties’ a short enlargement of time until November 23, 2020 to file these
documents. This is plaintiff’s second request for an extension of time for the parties to file these
documents, and it the first request made jointly on behalf of all parties.
We thank the Court for its consideration of this matter.

Application granted.

Respectfully submitted,

SO ORDERED.

/s
DAVID M. HAZAN, ESQ.

____________________________
Philip M. Halpern, U.S.D.J.
Dated: New York, NY
November 19, 2020

www.jacobshazan.com