Jacobs et al v. City of New York et al

Filing 39

ORDER granting 38 Letter Motion to Stay. APPLICATION GRANTED. SO ORDERED. (Signed by Judge Vernon S. Broderick on 10/2/2020) (rro)

Case 1:18-cv-03275-VSB Document 38 Filed 09/30/20 Page 1eeplaw.com
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80 Pine Street, 38th Floor
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New Jersey Office
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JOHN ELEFTERAKIS*
NICHOLAS ELEFTERAKIS
RAYMOND PANEK
OLIVER R. TOBIAS
JEFFREY B. BROMFELD
FAIZAN GHAZNAVI
GABRIEL P. HARVIS
BAREE N. FETT
STEPHEN KAHN
EVAN M. LA PENNA

September 30, 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:

10/2/2020

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

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, along with Gabriel Harvis and Jeffrey Rothman, represent plaintiffs in the
above-referenced action. Pursuant to the Court’s order dated June 29, 2020, I write on
behalf of the parties to provide a status report and to respectfully request that the stay
be extended until November 30, 2020.
The parties have continued to work cooperatively to exchange documents and
material so that plaintiffs’ out-of-state ballistics expert may conduct his forensic
evaluation in New York. Unfortunately given the delays caused by the Covid-19
pandemic, including that plaintiffs’ expert is traveling from out-of-state, our progress
has been slower than anticipated. We are hopeful, however, that the ballistics evaluation
can be completed within the next sixty days.
Accordingly, the parties respectfully request that the stay be extended until
November 30, 2020, at which time the parties further request that they be permitted to
submit a joint status letter advising of our progress.
Respectfully submitted,
cc:

All Counsel

Baree N. Fett