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<blockquote data-quote="Deset Gled" data-source="post: 8977801" data-attributes="member: 7808"><p>Looks like an extension until April 18. Formatting, emphasis, and minor editing by me:</p><p></p><p>-----</p><p>I am Bernard V. Kleinman, Esq., attorney of record for the named Plaintiffs [Lanasa] herein.</p><p></p><p>I submit this Affirmation in support of counsel’s motion for an extension of time in which to respond to Defendants’ Rule 12(b) Motion to Dismiss. Pursuant to the Court’s Rules Part II.E., regarding Requests for Extensions:</p><p></p><p>(1) <strong>Defendants’ Rule 12 Motion was filed on March 8, 2023</strong>. As such the Plaintiffs’ Response is due, as per the Court’s Scheduling Order of February 22, 2023, on or before April 4, 2023.</p><p>(2) The reason for this request for an extension is that Plaintiffs’ counsel has undergone a number of medical emergencies directly impacting his ability to fully complete the Response on the current schedule. On March 7th, 2023, Affirmant was diagnosed with acute pneumonia. This condition existed in an exaggerated and dire state for the next ten days, and Affirmant is till undergoing the lasting effects of the pneumonia. Secondly, on March 29, 2023, Affirmant was treated at Northern Westchester Hospital for severe and disabling lower</p><p>back pain. Affirmant has undergone two surgeries in the past several years for severe and disabling back conditions. As a result of the hospital visit on March 29, Affirmant has been prescribed heavy pain meds, and is unable to be in a sitting condition (and work at his desk) for more than fifteen minutes at a time.</p><p>(3) Affirmant is requesting an extension of time to April 18, 2023, two weeks from the original date.</p><p>-----</p><p></p><p>It's worth noting that this shows that [USER=15047]@tenkar[/USER] filed a formal motion to dismiss on March 8th. For whatever reason, I can't see that on PACER. I'm sure it's a good read.</p></blockquote><p></p>
[QUOTE="Deset Gled, post: 8977801, member: 7808"] Looks like an extension until April 18. Formatting, emphasis, and minor editing by me: ----- I am Bernard V. Kleinman, Esq., attorney of record for the named Plaintiffs [Lanasa] herein. I submit this Affirmation in support of counsel’s motion for an extension of time in which to respond to Defendants’ Rule 12(b) Motion to Dismiss. Pursuant to the Court’s Rules Part II.E., regarding Requests for Extensions: (1) [B]Defendants’ Rule 12 Motion was filed on March 8, 2023[/B]. As such the Plaintiffs’ Response is due, as per the Court’s Scheduling Order of February 22, 2023, on or before April 4, 2023. (2) The reason for this request for an extension is that Plaintiffs’ counsel has undergone a number of medical emergencies directly impacting his ability to fully complete the Response on the current schedule. On March 7th, 2023, Affirmant was diagnosed with acute pneumonia. This condition existed in an exaggerated and dire state for the next ten days, and Affirmant is till undergoing the lasting effects of the pneumonia. Secondly, on March 29, 2023, Affirmant was treated at Northern Westchester Hospital for severe and disabling lower back pain. Affirmant has undergone two surgeries in the past several years for severe and disabling back conditions. As a result of the hospital visit on March 29, Affirmant has been prescribed heavy pain meds, and is unable to be in a sitting condition (and work at his desk) for more than fifteen minutes at a time. (3) Affirmant is requesting an extension of time to April 18, 2023, two weeks from the original date. ----- It's worth noting that this shows that [USER=15047]@tenkar[/USER] filed a formal motion to dismiss on March 8th. For whatever reason, I can't see that on PACER. I'm sure it's a good read. [/QUOTE]
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