¶
April 23, 2020¶
VIA ECF¶
Hon. Lorna G. Schofield United States District Judge Thurgood Marshall United States Courthouse 40 Foley Square New York, New York 10007¶
Re: 19-cv-10475 (LGS-DCF), v. Darren. Indyke, et at
¶
Haddon, and e c Laura A. Menninger¶
150 Eost 10th Avenue Denver. Colorado 80203 PH 303.831.7364 DC 303.832.2628 www.hmflow.com Imenningerehmflow.com¶
Dear Judge Schofield:¶
Pursuant to this Court's directive at the conference held on April 16, 2020, I write to advise the Court that Ms. Maxwell intends to file a motion to dismiss under Fed. R. Civ. P. 12.¶
While the defenses we intend to raise by pm-answer motion may be asserted and preserved in an answer, we respectfully submit that it promotes efficiency and conserves the parties' resources for Ms. Maxwell to assert some defenses now, e.g., meritorious arguments that one or more claims are legally deficient or venue is improper.¶
Counsel respectfully suggests a briefing schedule wherein the Motion is filed by May 14, plaintiff responds by June 4, and the reply is due June 18.¶
Respectfully Submitted,¶
C. Laura A. Menninger¶
CC: Counsel of Record via ECF¶