Leonard B. Sand
ROSEN LIVINGSTON & CHOLST LLP
ATTORNEYS AT LAW
MORTON H. ROSEN
PETER I. LIVINGSTON
BRUCE A. CHOLST
MARY L. KOSMARK
ANDREW B. FREEDLAND
DEBORAH B. KOPLOVITZ
ANDREW J. WAGNER
ELLIOT J. COZ
S. DAVID HARRISON
Of Counsel
ALAN M. GOLDBERG
Special Counsel
TARA TESTAVERDE
INNA GRINBERG
Paralegals
VIA HAND DELIVERY The Honorable Leonard B. Sand
United States District Judge, Southern District of New York
United States Courthouse
Dear Judge Sand:
This firm represents all fifteen Defendants in the-above captioned ease. We write to Your Honor to respectfully request an enlargement of our opening memorandum of law which will be submitted in support of an upcoming pre-answer motion to dismiss the Amended Complaint.
Although we are permitted 25 pages pursuant to Section 2.C of Your Honor's Individual Rules, we will not be able to do so given the fact that Plaintiff has brought six different causes of action on his behalf and on behalf of a "Jane Doe" under several different statutory schemes each with very complex legal requirements, and most are against different groups of defendants. Accordingly, we therefore write to respectfully request an enlargement of the opening brief to 35 pages, not including the table of contents and authorities.
We hope that this request meets with Your Honor's approval.
Respectfully Submitted,
Deborah B. Koplovitz cc. Bryan Arbeit, Esq. via email