Oakley v. Dolan ( 2020 )

GIBSON DUNN Gibson, Dunn & Crutcher LLP 200 Park Avenue New York, NY 10166-0193 Tel 212.351.4000 www.gibsondunn.com December 24, 2020 Randy M. Mastro Direct: +1 212.351.3825 Fax: +1 212.351.5219 VIA ECF AND E-MAIL (CA02_RJSChambers@ca2.uscourts.gov) RMastro@gibsondunn.com Hon. Richard J. Sullivan United States Circuit Judge 500 Pearl St., Room 2530 New York, New York 10007 Re: Oakley v. MSG Networks, Inc., et al., 17-cv-6903 (RJS) Dear Judge Sullivan: I write as Defendants’ counsel, pursuant to Your Honor’s Rule 1(C), to request that Defendants’ time to serve their answer to Plaintiff Charles Oakley’s Amended Complaint be stayed and ex- tended to, and including, Monday, January 11, 2021. Plaintiffs counsel has consented to this re- quest, and this is our first request for such an extension. Plaintiffs counsel 1s still considering our further request to stay our clients’ obligation to answer until after disposition of Defendants’ summary judgment motion, which we believe would be con- sistent with this Court’s recent order staying discovery (Dkt. No. 90), and consistent with the ef- fect that a dispositive motion would typically have (see Rashidi v. Albright, 818 F. Supp. 1354, 1357 (D. Nev. 1993) (“Reasons exist for the postponement of the responsive pleading until the de- termination of a motion for summary judgment which will be entirely dispositive of the action if the rules are construed as required by Fed. R. Civ. P. 1 to secure the just, speedy and inexpensive determination of every action.”)). As always, we appreciate the Court’s consideration of this request. Respectfully, /s/ Randy M. Mastro Randy M. Mastro ce: All Counsel of Record (via ECF) IT IS HEREBY ORDERED THAT Defendants shall serve their answer to Plaintiff's Amended Complaint by Monday, January 11, 2021. The Court will consider any further extension once Defendants' counsel has learned of Plaintiff's position regarding any such extension. Dated: December 28, 2020 New York, New York SO ORDERED: RICHARD J. SULLIVAN U.S.C_J., Sitting by Designation Beijing * Brussels » Century City » Dallas * Denver * Dubai + Frankfurt » Hong Kong * Houston * London □ Los Angeles » Munich New VYark « Orance Cniinty « Paln Altn « Paric « San Franriern e San Pailin « Singannre « Wachinotnn DNC