Schoolcraft v. The City Of New York et al

Filing 451

FILING ERROR - WRONG EVENT TYPE SELECTED FROM MENU - LETTER RESPONSE to Motion addressed to Judge Robert W. Sweet from Walter Kretz dated July 8, 2015 re: 443 LETTER MOTION for Conference addressed to Judge Robert W. Sweet from Nathaniel B. Smith dated 6-2-2015. . Document filed by Steven Mauriello(Tax Id. 895117, Individually), Steven Mauriello(Tax Id. 895117 in his official capacity). (Kretz, Walter) Modified on 7/9/2015 (db).

SCOPPETTA SEIFF KRETZ & ABERCROMBIE
ERIC A. SEIFF
WALTER A. KRETZ, JR.
CHARLES D. ABERCROMBIE*
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444 MADISON AVENUE
30TH FLOOR
NEW YORK, NY 10022-1010
[phone]
FAX [phone]
---------ROLAND R. ACEVEDO
NICHOLAS SCOPPETTA

MARIANA OLENKO
--------* ALSO ADMITTED IN CT

OF COUNSEL

July 8, 2015
Honorable Robert W. Sweet
United States District Judge
United States District Court
Southern District of New York
500 Pearl Street
New York, NY 10007
Re:

Schoolcraft v. The City of New York, et al., 10-CV-6005 (RWS)

Dear Judge Sweet:
On behalf of defendant Steven Mauriello, I write in opposition to
plaintiff’s June 2, 2015, letter motion seeking reconsideration of portions of the Court’s
summary judgment Opinion filed on May 5, 2015. We join in the arguments presented
by the City Defendants in their July 6, 2015, papers in opposition to plaintiff’s motion for
reconsideration. The only issue raised on plaintiff’s motion that directly affects
defendant Mauriello is whether the Court correctly ruled that the individual defendants,
including Steven Mauriello, are protected by the doctrine of qualified immunity from any
liability on plaintiff’s First Amendment claim arising out of the defendants’ presuspension conduct. We join with the City Defendants’ in urging the Court to adhere to
its decision on this issue.
We therefore respectfully request that plaintiff’s motion for
reconsideration be denied in its entirety.
Respectfully submitted,

Walter A. Kretz, Jr.