Schoolcraft v. The City Of New York et al

Filing 595

LETTER addressed to Magistrate Judge Debra C. Freeman from Alan H.Scheiner dated March 17, 2016 re: Enlargement of Page Limits for Settlement Conference Submission, Email Submissions and Electronic Device Order. Document filed by The City Of New York. (Attachments: # 1 Text of Proposed Order Proposed Electronic Devices Order)(Scheiner, Alan)

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

March 17, 2016
By ECF
Magistrate Judge Debra Freeman
Unites States Magistrate Judge
Southern District of New York
500 Pearl St.
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, representing the motion respondent City of New York (the “City”), in connection
with the above-captioned matter.
I write with the following logistical requests for relief relating to the fee settlement
conference with Your Honor on March 22, 2016. All of the plaintiff’s counsel groups have
consented to these requests.
First, we respectfully request an elargement of the page limits in Your Honor’s individual
practices for the letter submission, from five pages to ten pages, excluding exhibits. This is
necessary because there are several legal and factual matters relating to the fee application as a
whole as well as the three distinct counsel groups. We believe that a minimum of 10 pages is
required for an adequate submission addressing the important facts relating to the fee application
of over 5,000 entries and the principal legal issues. (Even 10 pages is a difficult fit.)
Second, we respectfully request permission to make the submission to Your Honor by
email and/or by online drop box.
Third, we respectfully request an order permitting the attending counsel to bring electronic
equipment to the conference in the form of a laptop, cell phone (including an iPhone), and/or
tablet. A proposed order for the City’s counsel is attached.

We thank the Court for its consideration of this matter.
Respectfully submitted,
/s/
Alan H. Scheiner
Senior Counsel

cc: All Counsel by ECF

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