gov.uscourts.nysd.447706.624.0.pdf

Case 1:15-cv-07433-LAP Document 624 Filed 02/14/17 Page 1 of 2 Haddon, Morgan and Foreman, P.c Jeffrey S. Pagliuca HADDON FILED 150 East l 0th Aven ue MORGAN Den ver, Colorad o 80203 PH 303.83 1.7364 FX 303.832 .2628 jrnl (l~ao1~uc~@hm@f"~ F OREMAN _ _ _www..bo:i.fla w..cow r. I~« I !: l February 10, 2017 Lf\_ l !_!::; Via Email . . -··- c.:. ' Hon. Robert W. Sweet United States District Judge United States District Court Daniel Patrick Moynihan Courthouse Southern District of New York 500 Pearl Street, Room 1940 New York, New York 10007-1312 Re: Giuffre v. Maxwell, l 5-cv-07433-R WS Dear Judge Sweet: I am writing to request a five day , unopposed, extension of time to respond to "Plaintiffs Motion to Exclude Designation of Deposition Excerpts of Alan Dershowitz in an Unrelated Case" (ECF 561) and "Plaintiffs Motion to Exclude Defendant's Designation of Deposition Excerpts of Virginia Giuffre in an Unrelated Case" (ECF 563). A number of filings by Defendant were due on February 10, 2017 (today) including Defendant' s replies to six motions related to expert testimony and her reply in support of her motion for summary judgment. In addition, the Joint Pretrial Order is also due today and will be submitted by the parties. The issues raised by motions in limine and summary judgment are scheduled to be argued on February 16, 2016, making these responses a priority. In addition, I am hopeful that the issues raised in the motions to exclude the designations can be resolved between the parties after a conferral. On February 10, 2016 I conferred with counsel for the Plaintiff, Ms. Mccawley, who indicated that she had no objection to this request. Respectfully Submitted, HADDON, MORGAN AND FOREMAN, P. C. Isl Jeffrey S. Pagliuca Jeffrey S. Pagliuca Case 1:15-cv-07433-LAP Document 624 Filed 02/14/17 Page 2 of 2 Hon. Robert W. Sweet February 10, 2017 Page 2 CERTIFICATE OF SERVICE I certify that on February 10, 2017, I electronically served this LETTER MOTION via ELECTRONIC MAIL on the following: Sigrid S. Mccawley Paul G. Cassell Meredith Schultz 383 S. University Street BOIES, SCHILLER & FLEXNER, LLP Salt Lake City, UT 84112 401 East Las Olas Boulevard, Ste. 1200 [email protected] Ft. Lauderdale, FL 33301 [email protected] [email protected] J. Stanley Pottinger Bradley J. Edwards 49 Twin Lakes Rd. FARMER, JAFFE, WEIS SING, EDWARDS, South Salem, NY 10590 FISTOS & LEHRMAN, P.L. [email protected] 425 North Andrews Ave. , Ste. 2 Ft. Lauderdale, FL 33301 [email protected] Isl Nicole Simmons Nicole Simmons