Colon v. City Of New York

Filing 204

ORDER granting 203 Letter Motion for Local Rule 37.2 Conference. APPLICATION GRANTED. A telephonic conference is scheduled for August 5, 2021, at 3:00 p.m. The dial-in number for the conference is 888-363-4749 and the access code 2682448. In adv ance of the conference, the parties shall submit a joint letter of no more than 5 pages on ECF by on or before July 29, 2021 outlining their dispute. SO ORDERED. Telephone Conference set for 8/5/2021 at 03:00 PM before Judge Vernon S. Broderick. (Signed by Judge Vernon S. Broderick on 7/20/2021) (vfr)

Case 1:16-cv-04540-VSB-OTW Document 204 Filed 07/20/21 Page 1 of 2

Welcome

NEW YORK CITY HOUSING AUTHORITY
LAW DEPARTMENT
90 CHURCH STREET$ NEW YORK, NY 10007

NEW YORK CITY

HOUSING
AUTHORITY

http:/nyc.gov/nycha

GREGORY P. RUSS
Chair & CEO

WRITER’S DIRECT LINE
[phone]

LISA BOVA-HIATT
EVP of Legal Affairs and General Counsel

July 19, 2021
VIA CM/ECF

7/20/2021
A telephonic conference is scheduled for August 5,
2021, at 3:00 p.m. The dial-in number for the
conference is 888-363-4749 and the access code
2682448. In advance of the conference, the parties
shall submit a joint letter of no more than 5 pages on
ECF by on or before July 29, 2021 outlining their
dispute.

Hon. Vernon S. Broderick, U.S.D.J.
United States District Court
Southern District of New York
Thurgood Marshall United States Courthouse
40 Foley Square, Courtroom 518
New York, NY 10007
Re:

Sibyl Colon v. City of New York, et al. No. 16-CV-4540 (VSB)(OTW)
Joint Request For Informal Discovery Conference With the Court

Dear Judge Broderick:
I am counsel of record for Defendant the New York City Housing Authority (“NYCHA”) in the
above-referenced matter. With the consent of Plaintiff’s counsel, I respectfully submit this joint letter
seeking an informal discovery conference with the Court in lieu of the parties’ joint status update and
proposed discovery schedule, which was due to be filed today in accordance with your Your Honor’s
Opinion and Order dated May 26, 2021, ECF No. 195, as modified by the deadline extensions granted by
the Court’s Orders of June 30, 2021 and July 13, 2021 (ECF Nos. 200 and 202, respectively).
The parties have met and conferred at length to discuss the scope and extent of the supplemental
discovery granted by Your Honor’s Opinion and Order dated May 26, 2021, and the obligations of the
parties thereunder. However, in light of the recent and untimely death of declarant Louis Nieves and the
cross-country relocation of declarant Robert Knapp – two percipient fact witnesses who were not timely
disclosed under the Rules and whose prejudicial testimony Plaintiff nevertheless intends to rely on at trial
– the Parties have a reached an impasse which we believe only the Court’s guidance can resolve.
To this end, in accordance with S.D.N.Y. Local Rule 37.2, the Parties respectfully request an
informal conference with the Court in the hope of settling their present dispute as it relates to the
supplemental discovery granted by Your Honor’s Opinion and Order dated May 26, 2021.
Respectfully submitted,
/s/ Sean-Patrick Wilson
Sean-Patrick Wilson (SW7862)
Lisa Bova-Hiatt, EVP of Legal Affairs and General Counsel $Law Department $Telephone [phone]

Case 1:16-cv-04540-VSB-OTW Document 204 Filed 07/20/21 Page 2 of 2

Associate General Counsel
New York City Housing Authority
Law Department
90 Church Street, 11th Floor
New York, NY 10007
Email: [e-mail]

cc: All Counsel of Record (via ECF)

2