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How does a plaintiff file a late response to a motion to dismiss that was filed by the defendant in NY federal court? If a plaintiff missses the 14-days deadline to file a response to the motion to dismiss, what alternatives does the plaintiff have? Can a plaintiff still submit a late response or wait for judge's decision and perhaps then file a motion for reconsideration? In a motion for reconsideration, does the plaintiff need a valid reason for missing the deadline for response to motion to dismiss? lastly, how does plaintiff allege that court's staff was biased against him/her by giving him/her wrong filing date for the complaint?