You are a paralegal working for the City Tech Legal Defense Group. Your supervising attorney, Dan Daffy, has asked you to draft a motion to dismiss pursuant to CPLR 3211. The attorney has informed you that he will be out of the country from May 15 through May 30.
Before drafting the motion, Mr. Daffy has asked you to look up the statutory time frame for filing this motion and has asked that you provide TWO (2) proposed return dates for the motion. The first is based on the 8-day statutory rule, and the second is based on the 16-day statutory rule.
Mr. Daffy also wants to know the due dates for a response by opposing counsel and the due dates for any reply.
Tips: 1. The motion must be returnable after the date of the assignment.
2. The motion must be returnable on a date the attorney is available to appear in court For example: Using the 8-day rule with a return date of April 29, 2023, the motion would be due to opposing counsel on April 21, 2023, and any response is due by April 27, 2023.