Schoolcraft v. The City Of New York et al

Filing 477

LETTER addressed to Judge Robert W. Sweet from Alan H. Scheiner dated August 14, 2015 re: Defendants' Joint Proposed Pretrial Order. Document filed by Christopher Broschart(Tax Id. 915354 in his official capacity), Christopher Broschart(Tax Id. 915354 Individually), Timothy Caughey(Tax Id. 885374 Individually), Timothy Caughey(Tax Id. 885374 in his official capacity), Kurt Duncan(Shield No. 2483, Individually), Kurt Duncan(Shield No. 2483 in his official capacity), William Gough(Tax Id. 919124, Individually), William Gough(Tax Id. 919124, in his Official Capacity), Elise Hanlon(in her official capacity as a lieutenant with the New York City Fire Department), Elise Hanlon(individually), Theodore Lauterborn(Tax Id. 897840 in his official capacity), Theodore Lauterborn(Tax Id. 897840, Individually), Michael Marino, Michael Marino, Gerald Nelson(Assistant Chief Patrol Borough Brooklyn North, Tax Id. 912370 in his official capacity), Gerald Nelson(Assistant Chief Patrol Borough Brooklyn North, Tax Id. 912370, Individually), Frederick Sawyer(Shield No. 2576 in his official capacity), Frederick Sawyer(Shield No. 2576, Individually), The City Of New York. (Attachments: # 1 Text of Proposed Order Defendants' Joint Proposed Pretrial Order)(Thadani, Kavin)

ZACHARY W. CARTER
Corporation Counsel

THE CITY OF NEW YORK

ALAN H. SCHEINER
Senior Counsel
phone: [phone]
fax: [phone]
[e-mail]

LAW DEPARTMENT
100 CHURCH STREET
NEW YORK, NY 10007

August 14, 2015
BY ECF & EMAIL
([e-mail])
Honorable Robert W. Sweet
United States District Judge
Southern District of New York
500 Pearl Street
New York, New York 10007
Re: Schoolcraft v. The City of New York, et al.
10-CV-6005 (RWS)
Your Honor:
I am a Senior Counsel in the office of Zachary W. Carter, Corporation Counsel of the
City of New York, assigned to represent City defendants in the above-referenced matter. I write
on behalf of all defendants to submit the enclosed proposed Joint Pre-Trial Order, pursuant to the
Court’s Individual Practices.
The proposed JPTO attempts to incorporate in good faith comments and information
from plaintiff to the extent that we have received any. For the reasons separately explained in
the City defendants’ opposition to plaintiff’s motion for an extension of time, also joined by all
defendants, the City defendants, joined by all defendants, respectfully request that the Court ‘So
Order’ defendants’ JPTO, notwithstanding plaintiff’s belated application for an extension of time
to file the JPTO.
Thank you for your consideration in this matter.
Respectfully submitted,
/s/
Alan H. Scheiner
Senior Counsel
Special Federal Litigation Division
Encl.

cc:

Nathaniel Smith (By E-Mail)
Attorney for Plaintiff
Gregory John Radomisli (By E-Mail)
MARTIN CLEARWATER & BELL LLP
Attorneys for Jamaica Hospital Medical Center
Brian Lee (By E-Mail)
IVONE, DEVINE & JENSEN, LLP
Attorneys for Dr. Isak Isakov
Matthew Koster (By E-Mail)
CALLAN, KOSTER, BRADY & BRENNAN, LLP
Attorneys for Lillian Aldana-Bernier
Walter A. Kretz , Jr. (By E-Mail)
SCOPPETTA SEIFF KRETZ & ABERCROMBIE
Attorney for Defendant Mauriello

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