Case 1:19-cv-05711-ER Document 41 Filed 04/08/21 Page 1 of 1
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`April 8, 2021
`
`VIA E_Mail
`
`
`The Honorable Edgardo Ramos
`Southern District of New York
`Thurgood Marshall U.S. Courthouse
` 40 Foley Square
`New York, New York 10007
`
`
`Re: Solomon Krow v. PineBridge Investments Holdings U.S. LLC et al; Case No. 19-cv-5711 (ER);
`
` Dear Judge Ramos:
`
`I am the pro se plaintiff in the action referenced above. I am writing to request that the period for
`completing discovery be re-opened for 60 days for the limited purpose of taking the deposition of
`Heather Buxton, whose Declaration defendant relies on in its Summary Judgment Motion filed on March
`30, 2021.
`
`Ms. Buxton was defendant PineBridge’s Head of Human Resources for the Americas during the period
`relevant to my claims. Through my pro bono attorneys, I made multiple attempts to serve Ms. Buxton
`with a notice of deposition. Several unsuccessful attempts were made to serve Ms. Buxton at
`residential addresses thought to have been current addresses for Ms. Buxton. I am attaching as exhibits
`hereto several affidavits from process servers who attempted to serve Ms. Buxton at different times
`without success. These attempts at service were made after we asked counsel for Defendant, Mr.
`Bernstein, if he would do the courtesy of assisting us either by accepting service on behalf of Ms. Buxton
`or providing us with a current address for Ms. Buxton. Mr. Bernstein declined to assist with our attempt
`to serve Ms. Buxton while apparently having an arrangement and understanding with Ms. Buxton that
`she would cooperate with Defendant by providing testimony in support of Defendant’s defenses.
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`As a pro se litigant, I lack the resources to chase potential witnesses, so I would request as a condition to
`including Ms. Buxton’s testimony on behalf of Defendant that she submit to being deposed by Plaintiff.
`The importance of Ms. Buxton’s testimony is evidenced by Defendant’s reliance thereon in support of its
`summary judgment motion.
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`If the Court grants this request, I propose that the deadline for filing my response to the Summary
`Judgment Motion be extended to 20 days following the date set by the Court for completing Ms.
`Buxton’s deposition. In the alternative, as a pro se plaintiff with a serious vision disability, I would
`request an extension to May 30 to prepare my response to Defendant’s Summary judgment motion.
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` Respectfully submitted,
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`s/ Solomon Krow, Pro Se
`
`75 Main Street, #203
`Woodbridge, N.J. 07095
`(732) 829-6802
`Skrow118@gmail.com
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`