`
`Brendan M. Walsh
`Member of the Firm
`bwalsh@pashmanstein.com
`Direct: 201.270.4948
`
`August 09, 2023
`
`VIA CM/ECF
`Magistrate Judge Jessica S. Allen
`United States District Court for the District of New Jersey
`Martin Luther King Federal Building & U.S. Courthouse
`50 Walnut Street
`Newark, NJ 07101
`
`Re:
`
`Zirvi v. Illumina, Inc., et al.
`Civil Action No.: 2:23-cv-01997 (MCA) (JSA)
`
`
`
`
`Dear Judge Allen:
`
`This firm and the firm of Akin Gump Strauss Hauer & Feld (Akin) serve as counsel for Defendants
`Akin, Matthew A. Pearson, and Angela Verrecchio in this matter. We write in response to the
`letter Plaintiff’s counsel filed on August 8, 2023 (ECF No. 65) to confirm and acknowledge that
`our firm has accepted service on behalf of Defendant Angela Verrecchio as of August 8, 2023 (the
`date of Plaintiff’s request).
`
`Additionally, we write pursuant to Local Civil Rule 6.1 to request that the Court extend Ms.
`Verrecchio’s deadline to answer, move, or otherwise respond to Plaintiff’s complaint from August
`29, 2023 to September 19, 2023. This request is being made before expiration of the period
`sought to be extended and is Ms. Verrecchio’s first extension request. This Court has ordered
`that “All Served Defendants shall answer, move, or otherwise respond to the Complaint on or
`before September 19, 2023.” (ECF No. 55.) Granting this request will make Ms. Verrecchio’s
`deadline the same as all other served parties (ECF Nos. 55 and 62), including the other two
`defendants our firm represents, which will facilitate the filing of a consolidated brief.
`
`We thank the Court for its courtesies and consideration of this request. If our request meets the
`Court’s approval, we ask that the Court so-order this letter below.
`
`Respectfully submitted,
`s/ Brendan M. Walsh
`Brendan M. Walsh
`
`
`
`Defendant Angela Verrecchio shall answer, move, or otherwise
`respond to the Complaint on or before September 19, 2023.
`SO ORDERED:
`
`_____________________________
`Honorable Jessica S. Allen, U.S.M.J.
`
`Court Plaza South
`21 Main Street, Suite 200
`Hackensack, NJ 07601
`
`
`Phone: 201.488.8200
`Fax: 201.488.5556
`www.pashmanstein.com
`
`
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