HUGHES JUSTICE COMPLEX • TELEPHONE: (609) 633-7786 • FAX: (609) 777-3607

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CHRIS CHRISTIE

Governor

State of New Jersey

OFFICE OF THE ATTORNEY GENERAL

DEPARTMENT OF LAW AND PUBLIC SAFETY

DIVISION OF LAW

JEFFREY S. CHIESA

Attorney General

KIM GUADAGNO

Lt. Governor

25 MARKET STREET

 PO BOX 112

TRENTON, NJ 08625-0112

CHRISTOPHER S. PORRINO

Director

May 15, 2013

VIA ELECTRONIC FILING AND REGULAR MAIL

Hon. Karen M. Williams, U.S.M.J.

Mitchell H. Cohen Federal Courthouse, Room 2040

1 John F. Gerry Plaza

Camden, New Jersey 08101

RE: Daniel Freid v New Jersey State Police

 Dkt. No. 11-cv-02578 (RMB)

Dear Judge Williams:

I represent the remaining defendants in the above referenced

matter. Pursuant to the most recent Scheduling Order issued by the

Court, the deposition of plaintiff's police practices expert,

Joseph Stine, is scheduled to take place on May 23, 2013.

Thereafter, dispositive motions are to be filed by June 24. I write

the Court seeking a short extension of those dates based upon the

following circumstances. 

As a result of exposure to the defoliant, Agent Orange, while

in Viet Nam between 1967 and 1969, I contracted both

arteriosclerotic heart disease and diabetes for which I receive

compensation. In January 2009, I underwent angioplasty during which

3 stents were placed in 2 separate coronary arteries which were

approximately 99% blocked. 

About two months ago, I began noticing symptoms similar to

those leading to that catherization and over this past weekend they

intensified. Yesterday, I went to my primary physician, who did an

EKG, and then sent me to my cardiologist. The cardiologist has

advised me to visit the emergency room of Clara Mass Hospital today

to be admitted for another angioplasty. He also advised me to do

nothing stressful or exert myself during the interim. 

Case 1:11-cv-02578-RMB-KMW Document 81 Filed 05/15/13 Page 1 of 2 PageID: 664
May 15, 2013

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Accordingly, I respectfully request that the Court extend

these dates for at least two weeks at this time to account for my

medical condition. I anticipate a return to work on May 28, subject

to my physical condition and the directions of my surgeon and

cardiologist. If that return date proves to be too optimistic, I

will communicate with the Court immediately so that further

adjustment of the scheduling can take place, if necessary. I have

not communicated these circumstances to opposing counsel prior to

this communication because they were both unexpected and occurred

very rapidly once I contacted my primary physician yesterday

morning for an appointment. 

I thank the Court for its consideration of this request and

its understanding of the situation.

Respectfully submitted,

JEFFREY S. CHIESA

ATTORNEY GENERAL OF NEW JERSEY

By: s/Vincent J. Rizzo, Jr. 

Vincent J. Rizzo, Jr. 

Deputy Attorney General

cc: Aaron Freiwald, Esq.

 Katherine Robinson, Esq.

Case 1:11-cv-02578-RMB-KMW Document 81 Filed 05/15/13 Page 2 of 2 PageID: 665