Dolcine v. Hanson

Opinion

VILIViE CHDUROLD DOCUMENT T. 242.532.1116 F. 212.532.1171 ELECTRONICALLY FILED New Jersey Office _ DOC *—__ hatha, Now □□□□□ 07928 ELEFTERAKIS DATE PILED: 12/5/2010 JOHN ELEFTERAKIS* ELEFTERAKIS NIGHOLAS ELEFTERAKIS PANEK | OLIVER R. TOBIAS JEFFREY B. BROMFELD FAIZAN GHAZNAVI GABRIEL P. HARVIS BAREE N. FETT December 3, 2019 EVAN ML LAYENNA BY ECF AKADANAYEVA Honorable Valerie KE. Caproni NHAEL INDELICATS United States District Judge MICHAEL MARRON Southern District of New York jOsebHy aeeny 40 Foley Square ws CUE □□□ New York, New York 10007 DANIEL SOLINSKY ANDREW VILLA Re: = Dotdne v. Hanson, et al, 17 CV 4835 (VEC) (JLC) “Also Admitted In New Jersey Your Honor: I represent plaintiff in the above-referenced action. I write, along with defendants, to respectfully request an extension of the discovery deadline from December 12, 2019 to February 3, 2020, along with a corresponding adjournment of the Pretrial Conference on December 13, 2019, to a date and time convenient to the Court after the close of discovery. This is the party’s second request for an extension of the discovery deadline. To date, hundreds of pages of documents along with audio material have been exchanged, and plaintiffs deposition was conducted. The deposition of defendant Ruffin is scheduled for December 4, 2019, and the parties are working cooperatively to schedule the remaining depositions of defendants Hanson and Donahue. Unfortunately, given counsels’ trial schedules’ along with the approaching holidays, the parties respectfully submit that a brief extension is needed to complete discovery.

" Counsel for defendants, Ms. Millar, was on trial from November 18 through 21, 2019, and engaged in preparation the week prior to trial; and Mr. Shaffer will be commencing a trial on December 9, 2019, which is expected to last approximately six days. The undersigned was also preparing for a trial in the wrongful conviction matter, Hamilton v. City of New York, 15 CV 4574 (CBA) (SJB), pending in the Eastern District of New York. The Hamilton trial was scheduled to commence on November 12, 2019, and

Accordingly, the parties respectfully request an extension of the discovery deadline until February 3, 2020, along with a corresponding adjournment of the Pretrial Conference. Thank you for your consideration of this request. x submitted, Batee N. Fett cc: All Counsel

Application GRANTED in part. The deadline to complete fact discovery is EXTENDED to December 31, 2019. The conference scheduled for December 13, 2019, is ADJOURNED to January 3, 2020, at 10:00 a.m. The parties’ joint preconference letter is due December 30, 2019. The Court will not grant further extensions absent extraordinary circumstances. SO ORDERED. Vide (G 12/4/2019 HON. VALERIE CAPRONI UNITED STATES DISTRICT JUDGE

counsel for plaintiff had been preparing for the trial - which was expected to continue for approximately three weeks — during September and October.