Jander v. International Business Machines Corporation et al

Filing 111

ORDER granting 110 Letter Motion to Stay re: 110 FIRST LETTER MOTION to Stay Pending Settlement addressed to Judge William H. Pauley, III from Samuel E. Bonderoff dated 02/22/2021. Application granted. All pending deadlines in th is case are stayed. The parties shall confer and submit to this Court a proposed schedule for preliminary approval, notice to class members, and final approval of the matter by March 8, 2021. SO ORDERED. (Signed by Judge William H. Pauley, III on 2/25/2021) (kv)

Attorneys at Law
50 Broadway, 32nd Floor
New York, New York 10004
Telephone [phone]
Facsimile [phone]
E-mail: [e-mail]
Website: www.Zamansky.com

Jacob H. Zamansky
Edward H. Glenn, Jr.
Samuel Bonderoff

Mohammad R. Nasereddin
Matthew P. Hendrickson

February 22, 2021

VIA ECF
Hon. Judge William H. Pauley III
Daniel Patrick Moynihan
United States Courthouse
500 Pearl Street, Room 1920
New York, New York 10007
Re:

Larry W. Jander and Richard J. Waksman v. Retirement Plans Committee of
IBM, Richard Carroll, Martin Schroeter, and Robert Weber
Civil Action No. 15-cv-3781 (WHP)

Dear Judge Pauley,
On behalf of plaintiffs Richard Waksman and Larry Jander and defendants Retirement
Plans Committee of IBM, Martin Schroeter, Richard Carroll and Robert Weber, we write to advise
the Court that, after engaging in mediation discussions with Robert Meyer of JAMS, the parties
have agreed in principle on a settlement of the above-titled matter.
To finalize the details of the settlement, as well as to prepare the initial papers seeking the
Court’s preliminary approval, the parties respectfully request a stay of all deadlines in the case.
The parties will confer and submit to the Court by March 8, 2021 a proposed schedule for
preliminary approval, notice to class members, and final approval of the matter. We are available
to further discuss the matter if the Court wishes to do so.

Hon. Judge William H. Pauley III
February 22, 2021
Page 2

Respectfully submitted,

ZAMANSKY LLC

DAVIS POLK & WARDWELL LLP

/s/ Samuel E. Bonderoff
Samuel E. Bonderoff
Jacob H. Zamansky
Edward H. Glenn, Jr.
50 Broadway, 32nd Floor
New York, New York 10004
Tel.: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]

/s/ Lawrence Portnoy
Lawrence Portnoy
Michael S. Flynn
Lindsay Schare
450 Lexington Avenue
New York, New York 10017
Tel.: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]

Attorneys for Plaintiffs

Attorneys for Defendants

Application granted. All pending deadlines in
this case are stayed. The parties shall confer and
submit to this Court a proposed schedule for
preliminary approval, notice to class members,
and final approval of the matter by March 8,
2021.