Emanuel et al v. Gap, Inc. et al

Filing 122

ORDER granting 121 Letter Motion for Extension of Time to File. Application granted. In compliance with the Court's Rules, Defendants shall file their pre-motion conference letter as well as a single document representing their Rule 5 6.1 Statement and the opposing party's responses thereto by April 19, 2021. Plaintiffs shall file their opposition letter by April 26, 2021. The Court shall hold a pre-motion conference on April 29, 2021 at 10:00 a.m. At the time of the scheduled conference all parties shall call [phone]; access code: 3456831. The Clerk is directed to terminate ECF No. 121. SO ORDERED.. (Signed by Judge Philip M. Halpern on 2/25/2021) (ks)

Case 7-19-cv-03617-PMH-LMS

Document 121

Filed in NYSD on 02/24/2021

Page 1 of 1

Application granted. In compliance with the Court's Rules,
Littler Mendelson, PC
Defendants shall file their pre-motion conference letter as
900 Third Avenue
well as a single document representing their Rule 56.1
New York, NY 10022.3298
Statement and the opposing party’s responses thereto by
April 19, 2021. Plaintiffs shall file their opposition letter by
April 26, 2021. The Court shall hold a pre-motion conference
Jean L. Schmidt
on April 29, 2021 at 10:00 a.m. At the time of the scheduled
212.497.8486 direct
conference all parties shall 212.583.9600 main
call [phone]; access code:
646.417.7534 fax
3456831. The Clerk is directed to terminate ECF No. 121.
[e-mail]

February 24, 2021
VIA ECF

SO ORDERED.

Hon. Phillip M. Halpern
United States District Court
Southern District of New York
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 10007-1312

________________________________
Philip M. Halpern, U.S.D.J.

Re:

Dated: White Plains, NY
February 25, 2021

Emanuel v. Gap, Inc., et al.

Case No.: 19-cv-03617-PMH-AEK

Dear Judge Halpern:
We represent Defendants Gap, Inc., Banana Republic, LLC, Michelle Russo, Toni Lynn Borowski
and Gregoire Jean-Louis (collectively “Defendants”) in connection with the above-referenced
matter.
Defendants intend to file a motion for summary judgment in this matter. Pursuant to Judge
Smith’s Case Management Order (Dkt. 101), the pre-motion letter is currently due March 5, 2021.
Pursuant to Rules 1(C) and (E)(vii) of your Honor’s individual rules, we write to request an
extension of time for Defendants to submit their pre-motion letter to April 19, 2021. The extension
is necessary to provide sufficient time for the Parties to prepare the required 56.1 Statement and
responses. Plaintiffs consent to this request.
We further write to request an adjournment of the telephonic conference scheduled before Your
Honor on March 24, 2021 at 10:00am to a date after April 26, which will be after Defendants’
submission of their pre-motion letter and Plaintiffs’ response to the letter. Plaintiffs consent to
this request.
We thank the Court for its time and consideration of this request.
Respectfully submitted,

/s/ Jean L. Schmidt
Jean L. Schmidt
cc:
Parisis G. Filippatos, Esq.