Larkin v. SailawayNY

Opinion

MUSA-OBREGON LAW, P.C. ATTORNEYS AND COUNSELORS AT LAW SHAUKY MICHAEL MUSA-OBREGON, ESQ. PETER KAPITONOV, ESQ. * admitted in NY/NJ MAYRA VELEZ, ESQ. KARL J. ASHANTI, ESQ. WWW.MUSA-OBREGON.COM MOLAWFIRM@GMAIL.COM *REPLY TO MASPETH OFFICE MASPETH OFFICE* MANHATTAN OFFICE WHITE PLAINS OFFICE 55-21 69T™ ST., 2" FL 757 THIRD AVE., 20™ FL 199 MAIN ST., SUITE 301 MASPETH, N.Y. 11378 NEW YORK, N.Y. 10017 WHITE PLAINS, N.Y. 10601 TEL (718) 803-1000 TEL (212) 655-4424 TEL (914) 380-1436 FAX (718) 374-6576 FAX (718) 374-6576 FAX (718) 374-6576 Application GRANTED. By October 18, 2023, Plaintiff's September 27, 2023 counsel shall submit evidence providing a factual basis for the attorney's fees award, including "contemporaneous billing BY ECF records documenting, for each attorney, the date, the hours Hon. Lorna G. Schofield, U.S.D.J. expended, and the nature of the work done." See Wolinsky v. United States District Court Scholastic Inc., 900 F. Supp. 2d 332, 336 (S.D.N.Y. 2012). Southern District of New York 500 Pearl Street Dated: September 27, 2023 New York, New York 10007 New York, New York Re: Erin Larkin, et al. v. Sailaway NY, et al., 22 CV 10737 LORNA G. SCHOFIEL UNITED STATES DISTRICT JUDG Dear Judge Schofield: Concerning Your Honor’s Order dated September 19, 2023 (ECF Document 37), the undersigned respectfully requests a brief extension of time to comply therewith. I am currently engaged in trial preparation, as I am scheduled to try a civil case before the Honorable Frederic Block in the Eastern District of New York that commences on Monday, October 2, 2023 in the matter of Jane Doe v. New York City Department of Education, et al., 21 CV 4332 (FB)(RML). As such, I have not yet had sufficient time to respond to the September 19" Order. This is the undersigned’s first request for an extension, and defense counsel has no objection thereto. Accordingly, the undersigned respectfully requests an extension of time until Wednesday, October 18, 2023, as the trial is expected to last two weeks. The undersigned thanks the Court for its time and consideration. Respectfully Submitted,

Karl J. Ashanti, Esq. Musa-Obregon Law, P.C.