# CUTI HECKER WANG LLP

305 BROADWAY, SUITE 607 NEW YORK, NY 10007 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
Mariann Meier Wang

cc: Bennet J. Moskowitz, Counsel for Defendants (by ECF)
documents/doj-14cd33beb2fbf9c0.pdf
{}