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  • Murphy V Onon. County - Plaintiff's Counsel Request (Time) Respond To Roberts J. Smith Esq. (8) Motions To Dismiss Filed 10-6-20 (Doc 106)

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    Desiree Yagan
    40 vizualizări2 pagini
    Plaintiff's Counsel Jarrod W. Smith Esq. Request sufficient time to properly respond to counsel's successive motion for each of 8 defendants to dismiss. Consistent with time granted to defendant's counsel Robert J. Smith Esq. to prepare and file motions.

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    Murphy v Onon. County __Plaintiff's Counsel Request [Time] Respond to Roberts J. Smith Esq. (8) Motions to Dismiss Filed 10-6-20 (Doc 106)

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    Plaintiff's Counsel Jarrod W. Smith Esq. Request sufficient time to properly respond to counsel's successive motion for each of 8 defendants to dismiss. Consistent with time granted to defendant's counsel Robert J. Smith Esq. to prepare and file motions.

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    40 vizualizări2 pagini

    Murphy V Onon. County - Plaintiff's Counsel Request (Time) Respond To Roberts J. Smith Esq. (8) Motions To Dismiss Filed 10-6-20 (Doc 106)

    Încărcat de

    Desiree Yagan
    Plaintiff's Counsel Jarrod W. Smith Esq. Request sufficient time to properly respond to counsel's successive motion for each of 8 defendants to dismiss. Consistent with time granted to defendant's counsel Robert J. Smith Esq. to prepare and file motions.

    Drepturi de autor:

    © All Rights Reserved
    Descărcați ca PDF, TXT sau citiți online pe Scribd
    Indicator pentru conținut neadecvat
    din 2

    Case 5:18-cv-01218-GLS-CFH Document 106 Filed 10/06/20 Page 1 of 2

    TEL: (315) 277-5370


    FAX: (315) 277-5395 PARRY & SMITH WEBSITE:
    WWW.JARRODWSMITH COM
    - ATTORNEYS AT LAW -
    JEFFREY R. PARRY, ESQ., PARTNER 1 1 SO. MAIN STREET • PO BOX 173 JARROD W. SMITH, ESQ., PARTNER
    JEFFREYPARRY4O4@GMAIL.COM JORDAN, NEW YORK 13080 JARRODSMITHLAW@GMAIL.COM

    October 6, 2020

    VIA ECF LETTER/MOTION ONLY

    Hon. Gary L. Sharpe


    U.S. District Court Judge
    Northern District of New York
    U.S. District Court
    445 Broadway
    Albany, New York 12207

    RE: Murphy v. Onondaga County et. al.


    Case No.: 18-cv-1218

    Dear Judge Sharpe:

    We represent Kevin Murphy regarding the above-referenced matter. Some of the


    Defendants have filed Motions to Dismiss on the pleadings. Motion hearing date has been set for
    November 19, 2020 and Plaintiffs responses are due November 2, 2020.

    On May 1, 2020, Robert J. Smith, Esq. and his law firm of Costello, Cooney, & Fearon,
    PLLC filed Notices of Appearance with the Court representing the following Defendants:
    Jonathan Anderson, Jammie Blumer, Jason Cassalia, Joseph Ciciarelli, Eugene Conway, Michael
    Dickinson, Roy Gratien and Joseph Peluso.

    On September 24, 2020, a little over 4 months since Mr. Smith filed his Notice of
    Appearance, he filed five (5) motions for dismissal of the complaint against the aforementioned
    Defendants on the pleadings. On September 25, 2020, again a little over 4 months since Mr. Smith
    filed his Notice of Appearance, he filed three (3) motions for dismissal of the complaint against
    the aforementioned Defendants on the pleadings.

    Plaintiff's counsel is requesting a four-month extension to provide adequate and proper


    responses to each set of papers for each Defendant aforementioned herein. This request is
    reasonable and consistent with the time the Defendants had to prepare and file their motions.

    Plaintiffs counsel is also requesting a stay of any and all scheduling orders that are now in
    place while we defend against these motions.

    FAYETTEVILLE OFFICE
    7030 EAST GENESEE STREET, SUITE 101
    FAYETTEVILLE, NEW YORK 13066
    PARRY & SMITH, L.L.C.
    Case 5:18-cv-01218-GLS-CFH Document 106 Filed 10/06/20 Page 2 of 2

    While I am not requesting a phone conference, if the Court would like to have one, I or in
    partner can make ourselves available for such a conference.

    Thank you for your consideration with our requests.

    PARRY & SMITH, L.L.C.

    Respectfully,

    SMITH, ESQ.

    JWS/
    cc: Defense counsel via ECF

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