Schoolcraft v. The City Of New York et al

Filing 505

LETTER addressed to Judge Robert W. Sweet from Alan H Scheiner dated September 22, 2015 re: Filing of Motion Papers Under Seal Pursuant to Protective Orders. Document filed by Christopher Broschart(Tax Id. 915354 in his official capacity), Kurt Duncan(Shield No. 2483, Individually), William Gough(Tax Id. 919124, Individually), Elise Hanlon(in her official capacity as a lieutenant with the New York City Fire Department), Shantel James(Shield No. 3004 in his official capacity), Theodore Lauterborn(Tax Id. 897840 in his official capacity), Michael Marino, Gerald Nelson(Assistant Chief Patrol Borough Brooklyn North, Tax Id. 912370 in his official capacity), Frederick Sawyer(Shield No. 2576 in his official capacity), The City Of New York. (Attachments: # 1 Exhibit Confidentiality Order, # 2 Exhibit Confidentiality Order, # 3 Exhibit Confidentiality Order)(Scheiner, Alan)

ZACHARY W. CARTER
Corporation Counsel

THE CITY OF NEW YORK

LAW DEPARTMENT
100 CHURCH STREET
NEW YORK, NY 10007

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

September 22, 2015
BY ECF
Honorable Robert W. Sweet
United States District Judge
Southern District of New York
500 Pearl Street
New York, New York 10007
Re: Schoolcraft v. 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 the City Defendants in the above-referenced matter. I
am writing to advise the Court that, pursuant to the signed Stipulation and Protective Order as to
Documents Produced by City Defendants (see Docket No. 105), the signed Stipulation and
Protective Order for Attorneys Eyes Only (see Docket No. 104), and the Stipulation and
Protective Order regarding expert materials of October 1, 2014 (see Docket No. 275) (all
enclosed), the City Defendants are filing the following under seal:
1. An unredacted version of City Defendants’ Memorandum of Law in Support of
their Motion In Limine to Preclude Plaintiff from Offering Certain Evidence at
Trial (see Docket No. 499).
2. Exhibit G and Plaintiff’s Trial Exhibits (“PTX”) 4, 6, 13, 16, 18, 22, 25, 26, 29,
30, 33, 34, 35, 40, 42, 46, 49, 50, 51, 52, 53, 54, 55, 57, 59, 60, 62, 64, 65, 66, 72,
84, 93, 95, 306, 308, 309, 314, 316, 400, 401, 402, 403, 406, 407, 408, 409, 420,
421, 426, and 427, which are referenced in City Defendants’ Memorandum of
Law in Support of their Motion In Limine to Preclude Plaintiff from Offering
Certain Evidence at Trial (see Docket No. 499).
3. An unredacted version of City Defendants’ Memorandum of Law in Support of
their Motion In Limine to Preclude Expert Testimony (see Docket No. 496).

Hon. Robert W. Sweet, U.S.D.J.
September 22, 2015
Page 2 of 2
4. Exhibit D, G, H, and I, and PTX 66, which are referenced in City Defendants’
Memorandum of Law in Support of their Motion In Limine to Preclude Expert
Testimony (see Docket No. 496).
A courtesy copy of these materials will be delivered to the Court’s chambers.
We thank the Court for its consideration in this matter.
Respectfully submitted,
/s/ Alan Scheiner________
Alan Scheiner
Senior Counsel
Encl.
cc:

All counsel (via ECF)