Kirkland-Hudson v. Mount Vernon City School District et al

Filing 106

ORDER granting 105 Letter Motion to Adjourn Conference. Granted. The summary judgment briefing schedule proposed herein is adopted. The 11/15/23 conference is adjourned sine die. So Ordered. (Signed by Judge Kenneth M. Karas on 11/14/23) (yv)

Case 7:21-cv-00695-KMK-AEK Document 105 Filed 11/14/23 Page 1 of 2

SILVERMAN I ATTORNEYS
&ASSOCIAT ES

AT LAW

November 14, 2023

VIAECF
The Honorable Kenneth M. Karas
United States District Court
Southern District ofNew York
300 Quarropas Street
White Plains, New York 10601

Re :

Kirkland-Hudson v. Mount Vernon City School District, et al.
Index No.: 21-CV-00695 (KMK)(AEK)
Our File No.: 5001.624

Dear Judge Karas :
We represent the Defendants in the above-referenced matter. We write jointly on behalf of
counsel for all parties to respectfully request that the conference currently scheduled for November
15, 2023 be adjourned sine die and that the Court so-order the proposed summary judgment motion
briefing schedule that is indicated below. In the alternative, the parties respectfully request that the
in-person conference be rescheduled as a telephone conference. This is the third request to adjourn
the conference and the first request to do so sine die with the substitution of a proposed briefing
schedule. Those prior requests have been granted.
As Your Honor is aware, the parties have engaged in settlement negotiations and
conferences before Judge Krause, and we appreciate the Court' s involvement and encouragement
of these conversations. At this time, however, the parties are unable to reach an agreement to
resolve the matter. As such, we respectfully request that a briefing schedule be entered for
Defendants' anticipated motion for summary judgment (see ECF 86).
The parties understand that the conference scheduled for November 15 is to set this briefing
schedule. Counsel have conferred and, 'with the upcoming holidays and counsels' pre-existing
schedules in mind, propose the following briefing schedule in lieu of a conference appearance to
set one:
-

Defendants' motion papers due January 12, 2024;
Plaintiff's opposition papers due March 8, 2024; and
Defendants' reply papers due March 22, 2024.

We thank the Court for its consideration of this request and apologize for the lateness of
its filing .

445 Hamilton Ave., Suite #1102 I White Plains, NY 10601
914.574.4510 Main I 914:,574.4515 Fax I silvermanandassociatesny.com

Case 7:21-cv-00695-KMK-AEK Document 105 Filed 11/14/23 Page 2 of 2
Kirkland-Hudson v. Mt. Vernon CSD, et al.
November 14, 2023
Page2

Respectfully submitted,

SILVERMAN & ASSOCIATES
By: Isl Deanna L. Collins
Deanna L. Collins
Attorneys for Defendants
[phone]
[e-mail]
TO:

all counsel of record (via ECF)
Granted. The summary judgment briefing schedule proposed
herein is adopted. The 11/15/23 conference is adjourned sine
die.

SILVERMAN ! ATTORNEYS
&ASSOCIATES

AT LA'N