ABC v. DEF

Filing 111

ORDER granting 110 Letter Motion to Adjourn Conference. Granted. The conference is adjourned to 11/16/22 at 11:00. Telephone Conference set for 11/16/2022 at 11:00 AM before Judge Kenneth M. Karas.. (Signed by Judge Kenneth M. Karas on 10/13/2022) (tro)

case 7:18-cv-08892-KMK-AEK Document 110 Filed 10/13/22 Page 1 of 1

Case 7:18-cv-08892-KMK-AEK Document 111 Filed 10/13/22 Page 1 of 1

::::_\·:, ,,: NIXON
-~ \"'¾, PEABODY
1

Nixon Pea body LLP
677 Broa d way, 10th Floo r
Alba ny, NY 12207 -2996
Attorneys at Law
nixonp, ,:,body. om
@NixonP, ab0dvLLP

Christopher J. Stevens
counsel

TI 518.427.2737
F / 83 3.755.3041
cstevens@ nixo n peabody. com

October 13 , 2022

BY ECF FILING
Hon. Kenneth Karas
United States District Judge
Southern District of New York
300 Quarropas Street
White Plains, New York 10601-4150
Re :

U.S . and State of New York ex rel. Munford v. Maranatha Human Svcs., et al.
18 CV 08892 (KMK) (AEK)

Dear Judge Karas:
We write,jointly with Relator's counsel, respectfully to request an adjournment of the
pre-motion conference currently scheduled for October 20, 2022, pertaining to Relator' s motion
for leave to amend her complaint. The parties jointly request an adjournment of the pre-motion
conference until after the close of fact discovery, which is currently scheduled to be completed
by November 14, 2022.
The parties do not anticipate that discovery will be impacted by a decision on Relator' s
motion. Therefore, given the amount of time the parties will need to dedicate to discovery in
this matter between now and November 14, 2022, with nearly a dozen depositions to take and
defend between now and then, we respectfully request that the pre-motion conference on
October 20th be adjourned to after November 14th.
Thank you for your consideration of this request.
Granted. The conference is adjourned to
111 llP 122, at

1}!;,de,ed
10/13/22

Respectfully submitted,

Ii ·.oo

Christopher J. Stevens
Counsel for Defendant Maranatha

Heidi A. Wendel
Heidi A. Wendel
Counsel for Relator Stephanie Munford
486 7-2775-9 16 I.I