Jacobs et al v. City of New York et al

Filing 35

ORDER granting 34 Letter Motion to Stay. APPLICATION GRANTED. SO ORDERED. The parties shall file a status update by June 30, 2020. The post-discovery conference scheduled for April 3, 2020 is adjourned sine die. (Signed by Judge Vernon S. Broderick on 3/24/2020) (rro)

Case 1:18-cv-03275-VSB Document 34 Filed 03/20/20 Page 1eeplaw.com 38th Floor
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JOHN ELEFTERAKIS*
NICHOLAS ELEFTERAKIS
RAYMOND PANEK

March 20, 2020
BY ECF
Honorable Vernon S. Broderick
United States District Judge
Southern District of New York
40 Foley Square
New York, New York 10007

Re:

Jacobs, et al. v. City of New York, et al., 18 CV 3275 (VSB)

OLIVER R. TOBIAS
JEFFREY B. BROMFELD
FAIZAN GHAZNAVI
GABRIEL P. HARVIS
BAREE N. FETT
STEPHEN KAHN
EVAN M. LA PENNA
KRISTEN PERRY – CONIGLIARO
AIKA DANAYEVA
ARIANA ELEFTERAKIS
MICHAEL INDELICATO
MICHAEL MARRON
DOMINICK MINGIONE
MARK NEWMAN
AGGELIKI E. NIKOLAIDIS
JOSEPH PERRY
MARIE LOUISE PRIOLO *
KEYONTE SUTHERLAND
WAYNE WATTLEY
*Also Admitted In New Jersey

Your Honor:
I represent plaintiffs in the above-referenced action. I write jointly with
defendants to respectfully request a 90-day stay of discovery and associated relief.
If it should please the Court, the parties have worked to complete the exchange
of paper discovery, and plaintiffs have forwarded records to a ballistics expert for
evaluation. While the parties have worked to minimize disruptions, both the review by
plaintiffs’ expert and the conduct of depositions have been complicated by the
developing COVID-19 pandemic.
The parties have conferred and believe a 90-day stay of discovery is prudent at
this time. Accordingly, the parties respectfully request that: 1) the Court enter a
discovery stay for 90 days; 2) permit the parties to submit a status letter at the conclusion
of that period as to whether a further stay is warranted; and 3) at the conclusion of the
stay, permit the parties to submit a jointly proposed discovery plan to govern the
remainder of these proceedings.
Thank you for your consideration of this request.
Respectfully submitted,
cc:

3/24/2020
All Counsel

The parties shall file a status update by June 30,
2020. The post-discovery conference scheduled for
April 3, 2020 is adjourned sine die.

Gabriel P. Harvis