Hay v. PBR Sales, LLC et al

Filing 32

ORDER granting 31 LETTER MOTION for Extension of Time to File Motion for Default Judgment addressed to Judge Kenneth M. Karas from Harold R. Burke dated 01/29/2020. Document filed by Monte Ting Hay. Granted. So ordered. (Signed by Judge Kenneth M. Karas on 1/30/2020) (rjm)

Case 7:18-cv-05736-KMK Document 31 Filed 01/29/20 Page 1 of 2

~LAw ~OFFICES OF HAR0LD~R.~BURKE~
POST OFFICE BOX 4078
GREENWICH, CONNECTICUT 06831
WWW. BURKE-LEGAL.COM

MEMO ENDORSED

MEMBER, STATE AND FEDERAL BARS OF
CONNECTICUT AND NEW YORK

TELEPHONE (203 ) 219-2301
FACSIMILE (203 ) 413-4443
E-MA IL HRB@ BURKE-LEGAL.COM

ViaECF
January 29, 2020

Hon. Kenneth M. Karas
United States District Court
300 Quarropas Street
White Plains, NY
Re:

Hay v. PBR Sales LLC et al.
Case No. 7:18-cv-05736-KMK

Dear Judge Karas:
This firm represents Plaintiff Monte Ting Hay in this above action.
I am respectfully requesting an extension oftime through February 14th in order to complet~
and file with the Court a motion for default judgment and all ancillary documents. This is the
Plaintiffs first such request.
I am making this request on account of a number of personal and professional issues that have
arisen since December 18 th , which include my active involvement in an elderly family member' s
recovery and care following a lengthy hospitalization, my preparation for and attendance at a trial
conducted last week in Connecticut, and extensive efforts undertaken to open and vacate a judgment
of foreclosure prior to my clients being ejected from their property. I have also requested and am
awaiting receipt of certain information from my client and do not know whether recent events in
Hong Kong and China (the ongoing protests in Hong Kong and now the coronavirus outbreak) will
impede either his ability to communicate with me of my ability to receive information from him.
Finally, as the Court may be aware, notices mailed by the Clerk to Mr. Sapra have been
returned as undelivered. Efforts are being undertaken to locate his whereabouts so that actual notice
of these proceedings can be made.
I anticipate that all documentation needed in support the motion for default judgment will be
available prior to February 14th in which case the motion will be filed as soon as it is ready.

Case 7:18-cv-05736-KMK Document 31 Filed 01/29/20 Page 2 of 2

~ - - - - -'Thank you for-your-consideration of this-request:-Should the €ourt--have-any-questions, we-ar·P---- -available to address them at the Court's convenience.
Respectfully,

~ f r ? ~.
Harold R. Burke
HRB/st
cc.

Client