Rochez et al v. BJ'S Wholesale Club, Inc.

Filing 35

MEMO ENDORSEMENT on JOINT DISCOVERY STATUS LETTER AND FORMAL REQUEST FOR SUBMISSION AND TRANSFER TO THE SDNY'S MEDIATION PROGRAM: granting 34 Motion for Discovery. ENDORSEMENT: Request GRANTED. The Court will refer this case to mediation b y separate Order. Discovery deadlines are adjourned as follows: expert discovery now due June 22, 2021; fact discovery and all discovery now due July 23, 2021; the case now shall be trial ready by December 13, 2021. So Ordered. (Signed by Magistrate Judge Stewart D. Aaron on 3/31/2021) (js)

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MORRISON MAHONEY LLP COUNSELLORS AT LAW Demi Sophocleous Direct Phone: 212-428-2498 Direct Fax: 646-576-8913 WALL STREET PLAZA 88 PINE STREET, SUITE 1900 NEW YORK, NEW YORK 10005 212-825-1212 FACSIMILE: 212-825-1313 NEW HAMPSHIRE MANCHESTER CONNECTICUT HARTFORD NEW YORK NEW YORK ENGLAND LONDON Robert E. Brann Direct Phone: 646-870-1743 Direct Fax: 646-588-0212 MASSACHUSETTS BOSTON FALL RIVER SPRINGFIELD WORCESTER RHODE ISLAND PROVIDENCE NEW JERSEY PARSIPPANY March 30, 2021 Via Electronic Filing The Honorable Stewart D. Aaron Daniel Patrick Moynihan United States Courthouse 500 Pearl Street Courtroom 21A New York, NY 10007-1312 Re: : 1 Rochez, et ano. v. BJ’s Wholesale Club Inc. 1:20-cv-03066-SDA JOINT DISCOVERY STATUS LETTER AND FORMAL REQUEST FOR SUBMISSION AND TRANSFER TO THE SDNY’S MEDIATION PROGRAM Dear Magistrate Judge Aaron: Our office represents the defendant, BJ’s Wholesale Club, Inc., in the above-referenced action. We submit this joint discovery letter - which has been reviewed and approved by plaintiffs’ counsel - pursuant to Your Honor’s initial Case Management Plan dated May 13, 2020, as well as the subsequent joint discovery letters submitted in this action. Moreover, we jointly submit this letter as a formal request for submission and transfer of the case into the SDNY’s Mediation Program. The parties have already engaged in preliminary settlement discussions and both offices believe mediation through the Court will prove useful in getting this case closer to an amicable resolution. At present, there are no outstanding demands for paper discovery from either party. Our office has been diligently pursuing our client to schedule the deposition of a party witness. Should the case not be transferred to the Mediation Program, we will undertake every effort to have a witness produced for a deposition in accordance with your prior discovery directives. The parties’ primary goal at this time is to have the case submitted to the Mediation Program in order to foster further settlement negotiations and to eventually settle the case. 1295372v.1 MORRISON MAHONEY LLP March 30, 2021 Page 2 However, in the event that the case is not transferred to the Mediation Program, the parties herein jointly agree that the following So-Ordered discovery timeline shall continue to be adhered to: Expert Discovery due by April 23, 2021 Fact Discovery due by May 24, 2021 All Discovery due by May 24, 2021 Prospective Trial Readiness date – October 25, 2021 We thank Your Honor for your time and consideration of the instant matter. Respectfully submitted, MORRISON MAHONEY LLP Demi Sophocleous Demi Sophocleous Robert E. Brann Robert E. Brann cc: Via E-Mail – Steven Falkoff Rosenberg Minc Falkoff & Wolff LLP Attorneys for Plaintiffs 122 E. 42nd Street New York, NY 10168 212-697-9280 Via E-Mail – and First-Class Mail Mediation Program United States District Court Southern District of New York 40 Foley Square, Suite 120 New York, New York 10007 1295372v.1

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