`NYSCEF DOC. NO. 30
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`INDEX NO. EF2021-269598
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`RECEIVED NYSCEF: 03/04/2024
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`Honorable Justin Corcoran
`Rensselaer County Supreme Court
`105 Third Street
`Troy, New York 12180
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`Tel: 800-686-9921
`Fax: 305-931-0877
`www.hermanlaw.com
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`March 4, 2024
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`Re: T.T. v. Hoosic Valley Central School District
`Index No. EF2021-269598
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`Dear Judge Corcoran:
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`This office represents the plaintiff, T.T., in the above-referenced action. We are writing to
`request that the deadline to conduct the deposition of our client be extended by an additional fifty
`(50) days, until April 30, 2024, or by any length of time deemed fit by this Court. Please be advised
`that we are making the within request with the consent of defense counsel, who is copied on this
`correspondence.
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`The reason for this request is that the undersigned attorney handling this matter, Ameer
`Benno, is currently on trial before Judge Muraca in Nassau County Supreme Court in the matter
`of J. G. v. Herricks Union Free School District (Index No. 900049/2020). That trial, which began
`last week, is expected to continue through at least the end of next week (March 15, 2024).
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`If the Court grants the within request, the parties respectfully request that the Note of Issue
`deadline likewise be extended by an additional sixty (60) days, until July 1, 2024 in order to allow
`for the completion of depositions and any post-deposition discovery.
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`Thank you for your time and attention to this matter.
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`Cc: Counsel of Record
`(Via NYSCEF)
`Daniel S. Rubin, Esq.
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`Respectfully submitted,
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`Ameer Benno, Esq.
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`Herman Law | California • Florida • New Jersey • New York
`1800 N. Military Trail, Suite 140, Boca Raton, Florida 33431
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