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Record

Draft: efta02737256

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

Draft: efta02737256

Other records

Prepared source

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 10007-1…