Sherman v. Town of Chester et al

Filing 125

ORDER granting 124 Letter Motion to Stay. The application is granted. (Signed by Judge Edgardo Ramos on 3/17/2020) (rro)

STEVEN C. STERN
[e-mail]
X
March 17, 2020
Via ECF
Honorable Edgardo Ramos
United States District Judge
Southern District of New York
40 Foley Square
New York, NY 10007
Re:

March 17, 2020

Sherman v. Town of Chester
Docket No. 12 cv 00647 (ER)(GWG)
File No. 080038

Your Honor:
This firm represents defendant in this matter. The parties recently re-engaged the Court’s
mediation program in the hope of resolving this case, and were assigned a mediator who is in the
process of scheduling our session. On behalf of both parties, we write to request a temporary stay
of discovery while the parties pursue settlement. This is our first request to stay discovery.
As the Court is aware, this case has a long and complicated history. Since discovery began,
the parties have been exchanging and reviewing upwards of 20,000 documents, and we understand
Plaintiff has a significant number of additional documents to produce. The case is expensive to
litigate, and will become more expensive as the parties move towards depositions and engage
experts. In addition to further anticipated delays resulting from the coronavirus pandemic, Mr.
Diederich’s father passed away last week. This stay would not only conserve resources, but allow
the parties to focus their time and attention on reaching a settlement. If settlement talks are
unsuccessful, we will promptly submit a joint proposed scheduling order to complete the
remaining discovery.
Thank you for your consideration of this matter.
Respectfully submitted,
SOKOLOFF STERN LLP

STEVEN C. STERN
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