Emanuel et al v. Gap, Inc. et al
Filing
124
ORDER granting in part and denying in part 123 Letter Motion for Extension of Time to File. Application granted in part. Defendant's pre-motion letter is due April 23, 2021; Plaintiff's opposition is due April 30, 2021. The parties' request to increase the page limit is denied. The April 29, 2021 conference is adjourned to May 17, 2021 at 12:00 p.m. SO ORDERED.. (Signed by Judge Philip M. Halpern on 4/19/2021) (ks)
Case 7:19-cv-03617-PMH-AEK Document 123 Filed 04/16/21 Page 1 of 2
April 16, 2021
VIA ECF
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
Re:
Emanuel v. Gap, Inc., et al.
Case No.: 19‐cv‐03617‐PMH‐AEK
Dear Judge Halpern:
Littler Mendelson, PC
900 Third Avenue
New York, NY 10022.3298
Jean L. Schmidt
212.497.8486 direct
212.583.9600 main
646.417.7534 fax
jschmidt@littler.com
Application granted in part. Defendant's pre-motion
letter is due April 23, 2021; Plaintiff's opposition is due
April 30, 2021. The parties' request to increase the
page limit is denied. The April 29, 2021 conference is
adjourned to May 17, 2021 at 12:00 p.m.
SO ORDERED.
_______________________
Philip M. Halpern
United States District Judge
Dated: White Plains, New York
April 19, 2021
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.
As your Honor is aware, 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 April 19, 2021
and Plaintiffs’ opposition is due April 26, 2021.
Pursuant to Rules 1(C) and (E)(vii) of your Honor’s individual rules, we write jointly with Plaintiffs to
request a brief extension of these dates. Specifically, the parties request that the date for Defendants’
submission of their pre‐motion letter be extended to April 23, 2021, and the date for Plaintiff’s opposition
be extended to April 30, 2021. The extension is necessary to provide sufficient time for Plaintiffs to
prepare its response to Defendants’ 56.1 Statement and allow time for Defendants to review Plaintiffs’
response before submission of the pre‐motion letter.
The parties further request to increase the page limit for the pre‐motion submissions to no more than
eight pages, double spaced. This request is made due to the fact this matter involves two Plaintiffs and is
fact intensive.
Lastly, the parties further request an adjournment of the telephonic conference scheduled before Your
Honor on April 29, 2021 at 10:00am to a date during the week of May 3, 2021, to which both parties are
fully available. Both parties are available from May 3 – 6th.
We thank the Court for its time and consideration.
Respectfully submitted,
Case 7:19-cv-03617-PMH-AEK Document 123 Filed 04/16/21 Page 2 of 2
April 16, 2021
Page 2
/s/ Jean L. Schmidt
Jean L. Schmidt
cc:
Parisis G. Filippatos, Esq.
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