Opinion
2:23-cv-00932-GMN-DJA
10-31-2023
LISE LOTTE-LUBLIN, LILI BERNARD, JANICE BAKER-KINNEY, REBECCA COOPER, LINDA KIRKPATRICK, JANICE DICKINSON, ANGELA LESLIE, PAM JOY ABEYTA, AND HEIDI THOMAS, Plaintiff, v. WILLIAM COSBY JR., Defendant.
MERSON LAW, PLLC By JORDAN RUTSKY Counsel for Plaintiff JENNIFER BONJEAN- Pro Hac Vice ASHLEY COHEN- Pro Hac Vice Bonjean Law Group, PLLC. Attorneys for Defendant
MERSON LAW, PLLC By JORDAN RUTSKY Counsel for Plaintiff
JENNIFER BONJEAN- Pro Hac Vice ASHLEY COHEN- Pro Hac Vice Bonjean Law Group, PLLC. Attorneys for Defendant
STIPULATION TO EXTEND DEFENDANT'S TIME TO ANSWER THE COMPLAINT
(FIRST REQUEST)
DANIEL J. ALBREGTS UNITED STATES MAGISTRATE JUDGE
IT IS HEREBY STIPULATED AND AGREED, by and between counsel for the Plaintiffs, Jordan Merson, Jordan Rutsky, Nathan Werksman, Alice Bohn, Manraj Sekhon, Brian Panish, Rahul Pavipudi, and Robert Glassman, for Lisa Lotte-Lublin, Lili Bernard, Janice Baker-Kinney, Rebecca Cooper, Linda Kirkpatrick, Janice Dickinson, Angela Leslie, Pam Joy Abeyta, and Heidi Thomas, (hereinafter “Plaintiff'), and Jennifer Bonjean and Ashley Cohen counsel for William Cosby Jr. (“the Defendant”) (collectively, “the Parties”), that the time for Defendant to respond to the Complaint be on or before November 30, 2023.
Denial of this request would deny defense counsel sufficient time to effectively and thoroughly prepare and submit pretrial motions and notices of defense, taking into account the exercise of due diligence.
The Stipulation is entered where counsel for the Defendant needs additional time to consult with her client. Defendant's advanced age (85 years old) and a myriad of health challenges, has resulted in limited opportunities for counsel to communicate with him. Furthermore, Defendant is currently residing a significant distance from counsel's New York office which adds an extra challenge to communication. Counsel needs additional time in which to consult and communicate with Defendant about how to Answer Plaintiff's complaint, which simply cannot be done by way of zoom.
Counsel for Plaintiff does not stipulate to the Defendant's reasoning set forth above but agrees to the extension of time proposed by the Defendant.
This is the First Stipulation for an extension to file an answer herein.
ORDER
IT IS THEREFORE ORDERED that the Defendant, William Cosby, Jr., herein shall have to and including November 30, 2023, to file an Answer to the Complaint in this matter.