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)

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ZACHARY W. CARTER Corporation Counsel THE CITY OF NEW YORK ALAN H. SCHEINER Senior Counsel phone: (212) 356-2344 fax: (212) 788-9776 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 Document9 -2- 03/17/16 5:13 PM

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