On January 31, 2019 a
Letter,Correspondence
was filed
involving a dispute between
Felina Robinson,
and
The Buffalo News, Inc.,
for Commercial Division
in the District Court of Erie County.
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Gardy & Notis, LLP
December 3, 2019 Attorneys at Law
Via ECF and FedEx
Hon. Timothy J. Walker
Supreme Court, Erie County
Part 22 - Fourth Floor
25 Delaware Avenue
Buffalo, New York 14202
Re: Robinson v. The Buffalo News, Inc.
No. 801427/2019
Dear Justice Walker:
This firm represents the plaintiff in the above matter. I write, after consultation with counsel for
Defendant, to request a short extension on Plaintiff’s time to file her motion for class certification.
Counsel for Defendant The Buffalo News, Inc. (“Defendant”) has consented to this extension.
The governing scheduling order sets the date for Plaintiff’s motion to be filed on December 5,
2019, and the close of class certification discovery falls on the same day as set at the parties’ October 4,
2019 scheduling conference.
Plaintiff and defendant have worked diligently throughout the class discovery period, and in
order to conserve party resources have stipulated to a set of facts relevant to class certification.
Today, however, it has come to the parties’ attention that certain facts in the stipulation may not
be accurate and thus the stipulation must be revised. This revision, in turn, will impact Plaintiff’s motion
for class certification and will require additional time for Plaintiff to conform the motion.
Accordingly, Plaintiff requests that the date for the completion of class certification discovery,
and the filing of the motion for class certification, be extended through and including December 13,
2019.
Thank you for your consideration of this matter.
Respectfully submitted,
Orin Kurtz
Gardy & Notis, LLP
Hon. Timothy J. Walker
December 3, 2019
Page 2
Orin Kurtz
cc: All Counsel (by Email)
Document Filed Date
December 03, 2019
Case Filing Date
January 31, 2019
Category
Commercial Division
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Tower 56 126 East 56th Street, 8th Floor New York, NY 10022 212 905 0509 T 212 905 0508 F www.gardylaw.com www.nyc-employmentlawyer.com Gardy & Notis, LLP December 3, 2019 Attorneys at Law Via ECF and FedEx Hon. Timothy J. Walker Supreme Court, Erie County Part 22 - Fourth Floor 25 Delaware Avenue Buffalo, New York 14202 Re: Robinson v. The Buffalo News, Inc. No. 801427/2019 Dear Justice Walker: This firm represents the plaintiff in the above matter. I write, after consultation with counsel for Defendant, to request a short extension on Plaintiff’s time to file her motion for class certification. Counsel for Defendant The Buffalo News, Inc. (“Defendant”) has consented to this extension. The governing scheduling order sets the date for Plaintiff’s motion to be filed on December 5, 2019, and the close of class certification discovery falls on the same day as set at the parties’ October 4, 2019 scheduling conference. Plaintiff and defendant have worked diligently throughout the class discovery period, and in order to conserve party resources have stipulated to a set of facts relevant to class certification. Today, however, it has come to the parties’ attention that certain facts in the stipulation may not be accurate and thus the stipulation must be revised. This revision, in turn, will impact Plaintiff’s motion for class certification and will require additional time for Plaintiff to conform the motion. Accordingly, Plaintiff requests that the date for the completion of class certification discovery, and the filing of the motion for class certification, be extended through and including December 13, 2019. Thank you for your consideration of this matter. Respectfully submitted, Orin Kurtz Gardy & Notis, LLP Hon. Timothy J. Walker December 3, 2019 Page 2 Orin Kurtz cc: All Counsel (by Email)