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JAVIER A. WHITE (1945-1987) 

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 GNOLEBA R. SERI * 

 DIDIER SEPHO◊

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January 21, 2011 

VIA ELECTRONIC FILING AND FAX (1-973-297-4906) 

Honorable Madeline Cox Arleo, United States Magistrate Judge 

United States District Court 

MARTIN LUTHER KING COURTHOUSE 

50 Walnut Street – Room 2060 

Newark, New Jersey 07101 

Re: Russell-Brown v. The University of Florida Board of Trustees et al., No. 10-cv04017-SDW-MCA 

Dear Judge Arleo: 

I represent Plaintiff Sherrie Russell-Brown in the above-referenced matter. Respectfully, I 

write to bring a time-sensitive issue to Your Honor’s attention, regarding Ms. Russell-Brown’s 

pending Motion to Amend/Correct (Dkt Entry No. 44), with a motion date of January 3, 2011, and 

the Defendants’, the University of Oxford (“Oxford”) and Oxford University Development (North 

America), Inc. (“Oxford NA”), Motions to Dismiss (Dkt Entry Nos. 46 and 47), with a motion date 

of February 7, 2011. Ms. Russell-Brown’s opposition brief is currently due this Monday, January 24, 

2011. 

Today, counsel for Defendants Oxford and Oxford NA requested that Ms. Russell-Brown 

consent to an extension of their motion date from February 7 to February 22, 2011. While Ms. 

Russell-Brown is not opposed to a short delay to file her opposition brief and for the Defendants 

Oxford and Oxford NA to file their reply briefs, she is not inclined to agree to a lengthier delay, 

because not all of the Defendants and allegations have been joined yet in this action. More 

specifically, Your Honor’s December 7, 2010 Text Order (Dkt Entry No. 43) struck Ms. RussellBrown’s Second and Third Amended Complaints (Dkt Entry Nos. 20 and 39) and directed the 

Defendants to re-file their motions to dismiss Ms. Russell-Brown’s First Amended Complaint (Dkt 

Entry No. 7) and/or their answers, on or before December 21, 2010. However, as explained in my 

December 9, 2010 letter to Your Honor (Dkt Entry No. 45), three of the eight Defendants, ALM 

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2

Media, LLC, William L. Pollak and Karen Sloan, are not named in the First Amended Complaint, 

because the factual allegations regarding those parties occurred subsequent to the filing of the First 

Amended Complaint, on August 31, 2010. An additional three of the eight Defendants, the 

University of Florida, Board of Trustees, the University of Florida, Levin College of Law, and 

Robert H. Jerry, II, were served with the stricken Third Amended Complaint but not the First 

Amended Complaint. Consequently, only two of the eight Defendants, Oxford and Oxford NA, refiled motions to dismiss, as directed by Your Honor. Which is why, in light of Your Honor’s 

December 7, 2010 Text Order, Ms. Russell-Brown immediately sought leave on December 9, 2010 

to file and serve her supplemental complaint. 

Again, in light of the Defendants’, Oxford and Oxford NA, request for an extension of their 

motion date, pushing this matter until the end of February, I wanted to bring the procedural posture 

of this case to Your Honor’s attention and to formally request a status conference, if Your Honor 

feels that that might be helpful. 

Thank you for your consideration. 

 

 Respectfully submitted, 

 

 s/ Lennox S. Hinds 

LSH/sbt 

cc: Zoë Eva Jasper, Esq., Attorney for Defendants the University of Oxford and Oxford 

University Development (North America), Inc. (via CM/ECF) 

 

Bruce S. Rosen, Esq., Attorney for Defendants ALM Media, LLC, William L. Pollak and 

Karen Sloan (via CM/ECF)

Ian S. Marx, Esq., Attorney for Defendants the University of Florida, Board of Trustees, the 

University of Florida, Levin College of Law and Robert H. Jerry, II (via CM/ECF)

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