Schoolcraft v. The City Of New York et al

Filing 608

LETTER addressed to Judge Robert W. Sweet from Alan H. Scheiner dated April 13, 2016 re: Requested Correction. Document filed by The City Of New York. (Attachments: # 1 Exhibit Corrected Exhibit DD)(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

April 13, 2016
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. Jamaica Hospital Medical Center, 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 to advise the Court that due to a typographical error in a spreadsheet the wrong
amount was stated for the hourly rate of Magdalena Bauza in Exhibit DD to the City of New
York’s opposition to plaintiff’s fee application (Docket Nos. 598-28, 600-32), which stated $300
as the hourly rate instead of $100 as set forth in the City’s Memorandum of Law at 68-69
(“City’s Mem.) (Docket No. 597). This input error resulted in a mis-calculation of the proposed
fees, overstating the City’s proposed fee for Bauza’s time by $75,440, which was reflected in the
City’s Memorandum at 73. (In addition, footnote 52 on page 52 of the City’s Mem. incorrectly
referred to Exhibit DD where it should have referred to Exhibit BB.)
We respectfully request that the Court accept this letter and the attached corrected Exhibit
DD as an amendment to the City’s submission.

Sweet, J.
April 13, 2016
Page 2
We thank the Court for its consideration in this matter.
Respectfully submitted,
/s/
Alan H. Scheiner
Senior Counsel
Special Federal Litigation Division
Encl.
cc:

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