On May 25, 2021 a
Letter,Correspondence
was filed
involving a dispute between
St,
T. S.,
and
Brewster Central School District,
for Torts - Child Victims Act
in the District Court of Putnam County.
Preview
80 BROAD STREET, 23RD FLOOR
NEW YORK, NEW YORK 10004
(212) 509-3456 – TELEPHONE
(212) 509-4420 – FACSIMILE
www.mkcilaw.us.com
October 18, 2022
VIA EMAIL: judgesteinmanremote@nycourts.gov
Putnam Supreme and County Court
Honorable Leonard D. Steinman
20 County Center
Carmel Hamlet, NY 10512
RE: T.S. v. BREWSTER CENTRAL SCHOOL DISTRICT
Index No.: 500754/2021
Our File No.: 4184G-0072
Dear Hon. Steinman:
This office represents Defendant, Brewster Central School District in the above referenced
matter. Pending before the Court is Plaintiff’s counsel’s Order to Show Cause seeking to be
relieved as counsel, currently returnable before your Honor on November 3, 2022. While
Defendant has no objection to this Order to Show Cause being granted, Defendant would like to
respectfully request that should the Court be so inclined to grant Plaintiff’s counsel’s request, a
date certain be placed in the order relative to when Plaintiff must retain new counsel. Plaintiff’s
deposition, previously scheduled on September 20, 2022, was adjourned due to representations
made by counsel that their client did not want to proceed with his deposition, and the CPLR 3216
Order issued by the Court dated July 13, 2022 requires that a Note of Issue be filed within ninety
(90) days of that Order. To date, no depositions have been conducted, in large part due to
representations that Plaintiff was not prepared to proceed with his deposition and the litigation. If
Plaintiff does retain new counsel within a prescribed period of time as set forth by the Court, than
Defendant respectfully requests that a new scheduling order be submitted to the Court for approval
so that depositions can be completed, an IME can be conducted, and all outstanding discovery and
be completed.
FLORHAM PARK, NJ HARTFORD, CT WILMINGTON, DE SYRACUSE, NY
(973) 822-1110 (860) 404-3000 (315) 473-9648 (302) 656-1200
NEW YORK, NY PHILADELPHIA, PA SPARTA, NJ MIAMI, FL
(212) 509-3456 (215) 557-1990 (973) 726-4958 (305) 423-7189
{F2523771-1}
We thank the Court for its attention and continued courtesies in this matter. Should the
Court have any questions or require any additional information from the undersigned, please do
not hesitate to reach out.
Respectfully submitted,
McGIVNEY, KLUGER, CLARK &
INTOCCIA
Emily R. Weisslitz
EMILY R. WEISSLITZ ESQ.
eweisslitz@mkcilaw.us.com
cc: All Counsel of record (via EMAIL)
{F2523771-1} -2-
Document Filed Date
October 18, 2022
Case Filing Date
May 25, 2021
Category
Torts - Child Victims Act
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
80 BROAD STREET, 23RD FLOOR NEW YORK, NEW YORK 10004 (212) 509-3456 – TELEPHONE (212) 509-4420 – FACSIMILE www.mkcilaw.us.com October 18, 2022 VIA EMAIL: judgesteinmanremote@nycourts.gov Putnam Supreme and County Court Honorable Leonard D. Steinman 20 County Center Carmel Hamlet, NY 10512 RE: T.S. v. BREWSTER CENTRAL SCHOOL DISTRICT Index No.: 500754/2021 Our File No.: 4184G-0072 Dear Hon. Steinman: This office represents Defendant, Brewster Central School District in the above referenced matter. Pending before the Court is Plaintiff’s counsel’s Order to Show Cause seeking to be relieved as counsel, currently returnable before your Honor on November 3, 2022. While Defendant has no objection to this Order to Show Cause being granted, Defendant would like to respectfully request that should the Court be so inclined to grant Plaintiff’s counsel’s request, a date certain be placed in the order relative to when Plaintiff must retain new counsel. Plaintiff’s deposition, previously scheduled on September 20, 2022, was adjourned due to representations made by counsel that their client did not want to proceed with his deposition, and the CPLR 3216 Order issued by the Court dated July 13, 2022 requires that a Note of Issue be filed within ninety (90) days of that Order. To date, no depositions have been conducted, in large part due to representations that Plaintiff was not prepared to proceed with his deposition and the litigation. If Plaintiff does retain new counsel within a prescribed period of time as set forth by the Court, than Defendant respectfully requests that a new scheduling order be submitted to the Court for approval so that depositions can be completed, an IME can be conducted, and all outstanding discovery and be completed. FLORHAM PARK, NJ HARTFORD, CT WILMINGTON, DE SYRACUSE, NY (973) 822-1110 (860) 404-3000 (315) 473-9648 (302) 656-1200 NEW YORK, NY PHILADELPHIA, PA SPARTA, NJ MIAMI, FL (212) 509-3456 (215) 557-1990 (973) 726-4958 (305) 423-7189 {F2523771-1} We thank the Court for its attention and continued courtesies in this matter. Should the Court have any questions or require any additional information from the undersigned, please do not hesitate to reach out. Respectfully submitted, McGIVNEY, KLUGER, CLARK & INTOCCIA Emily R. Weisslitz EMILY R. WEISSLITZ ESQ. eweisslitz@mkcilaw.us.com cc: All Counsel of record (via EMAIL) {F2523771-1} -2-