Edrei et al v. Bratton et al

Filing 131

ORDER: granting 130 Letter Motion to Stay. Application GRANTED. To facilitate settlement discussions, the stay is extended to January 25, 2021. The parties shall advise the Court immediately in the event of a settlement and, in any event, shall submit a status letter no later than January 25, 2021. The Clerk of Court is directed to terminate ECF No. 130. SO ORDERED. (Signed by Judge Jesse M. Furman on 10/27/2020) (ama)

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Case 1:16-cv-01652-JMF Document 131 Filed 10/27/20 Page 1 of 2 THE CITY OF NEW YORK LAW DEPARTMENT JAMES E. JOHNSON Corporation Counsel 100 CHURCH STREET NEW YORK, NY 10007 PETER W. BROCKER Assistant Corporation Counsel T (212) 356-2332 F (212) 356-3509 E pbrocker@law.nyc.gov October 27, 2020 BY ECF: Hon. Jesse M. Furman, U.S.D.J. United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: Anika Edrei, et al. v. City of New York, et al., 16 Civ. 1652 (JMF) (BCM) Your Honor: I am an attorney assigned to the defense of the above referenced matter, and I write jointly with plaintiffs’ counsel to respectfully request that the Court extend the stay of this matter for an additional 90 days, from October 27, 2020 to January 25, 2020. This is the parties’ fourth application for a stay, but the first request to be based solely on the promising settlement negotiations that have already resulted in an oral agreement resolving the issues of plaintiffs’ damages and claims for equitable relief. This request, if granted, will enable the parties additional time to reduce the parties’ equitable relief agreements in principle to writing and attempt to resolve the sole remaining issue, plaintiffs’ attorneys’ fees, costs, and expenses. As the Court may recall, in the August 18, 2020 settlement conference, the parties agreed in principle on an award for plaintiffs’ damages, contingent on the parties’ successfully negotiating terms regarding equitable relief and plaintiffs’ attorneys’ fees, costs, and expenses. The parties recently resolved the issue of equitable relief in this matter, and are in the process of reducing their agreements to a written stipulation. If the Court grants this application, the parties plan to use the additional time to draft that stipulation and attempt to resolve this final issue of attorneys’ fees. The requested three-month adjournment is necessary because defendants need time to analyze plaintiff’s attorneys’ fees and then seek appropriate authority, and the parties will then need additional time to make their best efforts to come to an agreement, if possible, on their own, before attending a final settlement conference before Magistrate Judge Moses scheduled for January 11, 2021, if the parties cannot resolve the remaining issues in the case without assistance from the Court before then. 1 1 For the same reasons the parties sought and were granted an adjournment of the next settlement conference. The conference had been scheduled for October 20, 2020, but was adjourned to January 11, 2021. See, Dkt. No. 129. Case 1:16-cv-01652-JMF Document 131 Filed 10/27/20 Page 2 of 2 Thank you for your consideration of this matter. Respectfully Submitted, Peter W. Brocker /s// Peter W. Brocker, Esq. Assistant Corporation Counsel Application GRANTED. To facilitate settlement discussions, the stay is extended to January 25, 2021. The parties shall advise the Court immediately in the event of a settlement and, in any event, shall submit a status letter no later than January 25, 2021. The Clerk of Court is directed to terminate ECF No. 130. SO ORDERED. October 27, 2020 2

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