Home/Source documents/Extension of Time to File Answer, State of New York et al. v. U.S. Department of Education, No. 1:25-cv-02990 (S.D.N.Y.), Doc. 116 (June 12, 2025)
Extension of Time to File Answer, State of New York et al. v. U.S. Department of Education, No. 1:25-cv-02990 (S.D.N.Y.), Doc. 116 (June 12, 2025)
Full text
Case 1:25-cv-02990-ER Document 116 Filed 06/12/25 Page 1 of 2
U.S. Department of Justice
United States Attorney
Southern District of New York
86 Chambers Street, 3rd floor
New York, New York 10007
June 12, 2025
BY ECF
The Honorable Edgardo Ramos
United States District Court
Southern District of New York
Thurgood Marshall United States Courthouse
40 Foley Square
New York, New York 10007
Re: State of New York et al. v. U.S. Department of Education et al.,
No. 25 Civ. 2990 (ER)
Dear Judge Ramos:
This Office represents defendants in the above-referenced matter. We write
respectfully to request a 26-day extension of time, from June 13, 2025, to July 9, 2025, to
respond to the Complaint. The reason for this request is that the Government has appealed
the Court’s June 3 Preliminary Injunction Order, and has moved in the Second Circuit for
a stay of that Order pending resolution of the appeal. The Second Circuit has set an
expedited briefing schedule for the Government’s motion to stay, and has placed the
motion on the Court’s June 17, 2025 calendar. Because the Circuit’s ruling on the
Government’s motion may well affect the Government’s response to the Complaint and,
more generally, how the parties wish to proceed, we believe it would be most efficient to
delay the Government’s time to respond to the Complaint until after the Circuit has issued
a decision on the Government’s motion to stay.
In addition, we are requesting additional time to respond to the Complaint because
I will be traveling internationally to visit family from June 19 to July 5. We thus
respectfully request that our response be due the week after I return. This is the
Government’s first request for an extension of time regarding its response to the Complaint.
Plaintiffs consent to this request.
We thank the Court for its consideration of this request.
Case 1:25-cv-02990-ER Document 116 Filed 06/12/25 Page 2 of 2
Respectfully submitted,
JAY CLAYTON
United States Attorney for the
Southern District of New York
By: /s/ Dana Walsh Kumar
CHARLES S. JACOB
DANA WALSH KUMAR
Assistant United States Attorneys
86 Chambers Street, 3rd Floor
New York, New York 10007
Tel.: (212) 637-2725 / 2741
dana.walsh.kumar@usdoj.gov
charles.jacob@usdoj.gov
cc: Plaintiffs’ counsel (by ECF)
2