Wagner et al v. International Business Machines Corp.

Filing 70

ORDER granting 67 Letter Motion to Stay addressed to Judge Laura Taylor Swain from the Parties dated September 10, 2022. IT IS SO ORDERED. (Signed by Judge Laura Taylor Swain on 9/13/2022) (vfr)

Case 1:21-cv-09443-LTS-SLC Document 70
67 Filed 09/13/22
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September 10, 2022
VIA ECF
The Honorable Laura Taylor Swain
United States District Judge
United States District Court for the
Southern District of New York
500 Pearl St.
New York, NY 10007-1312

MEMO ENDORSED

Re: Wagner et al. v. International Business Machines Corp., Civil Action No. 1:21-cv-09443LTS-SLC
Dear Judge Swain:
Plaintiffs and Defendant International Business Machines Corporation (“IBM”) jointly
submit this letter motion to stay this proceeding. The parties have reached a tentative resolution,
and Plaintiffs anticipate filing stipulations of dismissal pursuant to Fed. R. Civ. P. 41 in the
coming weeks. As such, the parties respectfully request a full stay of the above captioned
proceeding, including suspension of all pending deadlines. The parties will likewise seek from
Magistrate Judge Cave an adjournment of the September 13, 2022, initial scheduling conference
based on this stay request. The parties further request that Your Honor issue no further
decisions, including any decisions relating to Defendant’s pending motions for judgment on the
pleadings (Dkt. Nos. 62, 65). The parties agree that a stay will further the interests of judicial
economy and efficiency and facilitate the final resolution of this matter. The parties further
agree to file either stipulations of dismissal or a status report by November 8, 2022.
If this joint request for a stay meets with Your Honor’s approval, a “So Ordered” line is
provided below for the Court’s convenience.

Case 1:21-cv-09443-LTS-SLC Document 70
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Page 2

Respectfully submitted,
/s/ Shannon Liss-Riordan
Shannon Liss-Riordan
Counsel for Plaintiffs
/s/ Matthew W. Lampe
Matthew W. Lampe
Counsel for Defendant
cc:
All counsel of record (via ECF)
IT IS SO ORDERED.
9/13/2022
DATED: ________________________

/s/ Laura Taylor Swain
____________________________________
Hon. Laura Taylor Swain
United States District Judge