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305 BROADWAY, SUITE 607
CUTI HECKER WANG LLP NEW YORK, NY 10007
MARIANN MEIER WANG
212.620.2603 TEL
212.620.2613 FAX
MWANG@CHWLLP.COM
March 16, 2020
By ECF
Hon. Debra Freeman
U.S. District Court for the Southern District of New York
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 10007-1312
Re: Davies v. Indyke et al., 19-cv-10788 (GHW)(DCF)
Your Honor:
We represent Plaintiff Teala Davies. With the consent of all parties,
we write respectfully to request a one-week extension of the briefing deadlines for
the Defendants’ pending motion to dismiss (ECF 26).
Plaintiff’s opposition papers are currently due on March 20 and
Defendants’ reply papers are currently due on March 30. We request a one-week
extension of both of those deadlines, so that Plaintiff’s opposition papers would be
due on March 27 and Defendants’ reply papers would be due on April 7. This
extension of time is needed due to challenges arising from COVID-19 response
measures, including school and office closures.
We have conferred with Bennet J. Moskowitz, counsel for Defendants,
and he consents to this extension. This extension would not affect any other
deadlines in this case. No previous extension of time has been requested since Your
Honor entered the parties’ proposed briefing schedule on February 28, 2020 (ECF
25).
We appreciate Your Honor’s attention to this matter.
Very truly yours,
/s/ Mariann Meier Wang
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