MARIANN MEIER WANG\
212.620.2603 TEL\
212.620.2613 FAX

MWANG@CHWLLP.COM

USDC SDNY\
DOCUMENT\
ELECTRONICALLY FILED\
DOC #: \_\_\_\_\_\
DATE FILED: 1/28/2020

*Before this Court sets a briefing schedule for a motion to dismiss, counsel are due to submit an update repaiding their settlement dismissions, specifically addressing the potential for their action being resolved without the need for motion practice.*

January 27, 2020

By ECF\
Hon. Debra Freeman\
U.S. District Court for the Southern District of New York\
Daniel [REDACTED] Moynihan\
United States Courthouse\
500 Pearl St.\
New York, NY 10007-1312

SO ORDERED: DATE: 1/28/2020

Re: [REDACTED] v. Indyke et al., 19-cv-10788 (GHWDCF)\
DEBRA FREEMAN

UNITED STATES MAGISTRATE JUDGE

Your Honor:

We represent Plaintiff [REDACTED] and write on behalf of all parties.

On January 21, 2020, Defendants submitted a pre-motion letter to Judge [REDACTED] proposing to file a motion to dismiss. (ECF 16). On January 22, Judge [REDACTED] issued an Amended Order Referring Case to Magistrate Judge clarifying that dispositive motions in this matter will be referred to Your Honor for Report & Recommendation. (ECF 17). It is our understanding of Your Honor's Individual Practices that no pre-motion letters are required for motions other than discovery motions, though Plaintiff's counsel is of course happy/prepared to submit one should Your Honor prefer that.

Accordingly, we write 1) to seek clarification that Plaintiff need not submit a letter in response to Defendants' January 21 pre-motion letter addressed to Judge [REDACTED], and 2) to propose the following briefing schedule for Defendants' motion:

- - Defendants' motion papers to be filed by February 25, 2020;
- - Plaintiffs' opposition papers to be filed by March 17, 2020;
- - Defendants' reply papers to be filed by March 31, 2020.

We appreciate Your Honor's attention to this matter.

Very truly yours,

/s/ Mariann Meier Wang