Dinkins v. Mayorkas

Filing 83

ORDER granting 82 Letter Motion to Stay. Application granted. To conserve resources, a stay of discovery is granted until September 24, 2024. The parties are to provide a joint update on the status but not the substance of their settlement talks within three business days of the settlement conference before Judge Wang. (Signed by Magistrate Judge Robyn F. Tarnofsky on 8/30/2024) (tro)

Ryan M. Jerome
Phone: [phone]
[e-mail]
www.saul.com

Application granted. To conserve resources,
a stay of discovery is granted until
September 24, 2024. The parties are to
provide a joint update on the status but not
the substance of their settlement talks
within three business days of the
settlement conference before Judge Wang.
Date: 08/30/2024
New York, NY

The Honorable Robyn F. Tarnofsky
Daniel Patrick Moynihan United States Courthouse
500 Pearl St.
New York, NY 10007-1312
RE:

Zaziiz S. L. Dinkins v. Alejandro Mayorkas,
1:23-cv-10660-RFT

Dear Judge Tarnofsky:
We represent Plaintiff Zaziiz S. L. Dinkins as pro bono counsel for the limited purpose of
conducting a settlement conference in the above-referenced matter. We, along with counsel for
Defendant Alejandro Mayorkas, United States Secretary of Homeland Security, submit this
update regarding the status of discovery pursuant to the Court’s case management plan (see ECF
No. 68) and, respectfully, request a brief stay of discovery in this matter pending settlement
discussions.
First, notwithstanding the appearance of the undersigned as pro bono counsel for
Plaintiff, the parties have engaged in limited discovery. On August 25, 2024, Plaintiff served
Defendant with her answers to Defendant’s interrogatories. Plaintiff has advised Defendant that
she is in the process of collecting additional responsive documents and information and will
produce them as soon as possible.
Second, on August 14, 2024, the parties appeared for a Pre-Settlement Conference
Scheduling Call with Judge Ona T. Wang, and on September 4, 2024, the parties will be
appearing for another Pre-Settlement Conference Call to formally schedule the settlement
conference. After conferring, the parties believe that there is a realistic opportunity to resolve this
matter at the settlement conference, which they intend to schedule for no later than September
24, 2024 (subject to Judge Wang’s availability), and thus, they respectfully seek a stay of
discovery pending completion of the settlement conference. The parties seek a stay of discovery
to allow them to conserve their time and resources to focus on the submission of mediation
statements and to prepare for the settlement conference. The parties are prepared to submit an
update to the Court promptly upon the completion of the settlement conference to advise as to
whether the matter has been resolved.

1270 Avenue of the Americas, Suite 2800



New York, NY 10020



Phone: [phone]



Fax: [phone]

CALIFORNIA DELAWARE FLORIDA ILLINOIS MARYLAND MASSACHUSETTS MINNESOTA NEW JERSEY NEW YORK PENNSYLVANIA WASHINGTON, DC
A DELAWARE LIMITED LIABILITY PARTNERSHIP

August 30, 2024
Page 2
We thank the Court for its attention to this matter and consideration of this request.

Sincerely,

Ryan M. Jerome
cc: All Counsel of Record (via ECF)