Jones et al v. United States Postal Service et al

Filing 85

LETTER addressed to Judge Victor Marrero from Rebecca S. Tinio dated October 9, 2020 re: Corrected Supplemental Guidance Document. Document filed by Louis DeJoy, Donald J. Trump, United States Postal Service. (Attachments: # 1 Exhibit A - Clean Version of Corrected Supplemental Guidance Document, # 2 Exhibit B - Redlined Version of Corrected Supplemental Guidance Document).(Tinio, Rebecca)

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Case 1:20-cv-06516-VM Document 85 Filed 10/09/20 Page 1 of 2 U.S. Department of Justice [Type text] United States Attorney Southern District of New York 86 Chambers Street, 3rd Floor New York, New York 10007 October 9, 2020 BY ECF Hon. Victor Marrero, United States District Judge United States District Court for the Southern District of New York Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, New York 10007-1312 Re: Jones et al. v. United States Postal Service et al., No. 20 Civ. 6516 (VM) Dear Judge Marrero: This Office represents the defendants in the above-referenced case. We write on behalf of all of the parties respectfully to request that the Court consider and, if it is acceptable to the Court, approve the attached corrected Supplemental Guidance Document. See Exhibit A (clean version). The attached corrected Supplemental Guidance Document would, if approved, supersede the version that the Court approved earlier today. See ECF No. 84. The parties apologize for the inconvenience to the Court. After the parties submitted their agreements regarding the Supplemental Guidance Document to the Court this afternoon, see ECF No. 83, Plaintiffs noted that the Supplemental Guidance Document contains language, elsewhere in that document, essentially identical to the provision that was the subject of the parties’ first agreement. See ECF No. 83-1 at 2 (bullet point relating to extra delivery and collection trips, as modified per the parties’ agreement); id. at 3 (unmodified provision titled “Delivery/Collections”). The parties have conferred and have agreed to modify the second instance of this language to match the first. A redline showing this additional change is attached as Exhibit B. The parties thank the Court for its consideration of these issues. Case 1:20-cv-06516-VM Document 85 Filed 10/09/20 Page 2 of 2 Page 2 of 2 Respectfully, COHEN&GREEN P.L.L.C. Attorneys for Plaintiffs By: /s/ J. Remy Green, Esq. J. REMY GREEN, ESQ. COHEN&GREEN P.L.L.C. 1639 Centre St., Suite 216 Ridgewood, New York 11385 Tel.: (929) 888.9480 Facsimile: (929) 888.9457 E-mail: remy@femmelaw.com AUDREY STRAUSS Acting United States Attorney for the Southern District of New York Attorney for Defendants By: /s/ Rebecca S. Tinio__ _ REBECCA S. TINIO STEVEN J. KOCHEVAR Assistant United States Attorneys 86 Chambers Street, Third Floor New York, New York 10007 Tel.: (212) 637-2774/2715 Facsimile: (212) 637-2686 E-mail: rebecca.tinio@usdoj.gov steven.kochevar@usdoj.gov

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