nied, because of inability to prepare for upcoming trial and risk of COVID-19); United States v. Chandler, 19-CR-867 (PAC), 2020 WL 1528120, at *1 (S.D.N.Y. Mar. 31, 2020) (releasing defendant on felon in possession case, with prior manslaughter conviction, due to inability to prepare for trial due to COVID-1

ch and the plaintiff's harm." Appel v. Schoernan Updike Kaufman Stern & Ascher L.L.P., No. 14-cv-2065 (MN), 2015 U.S. Dist. LEXIS 193133, at ■63-64 (S.D.N.Y. Mar. 26, 2015) (internal quotations and citations omitted). The Complaint fails to state a negligence claim because it fails to allege a duty held by E