Dinkins v. Mayorkas

Filing 87

ORDER granting 86 Letter Motion to Stay Application GRANTED. The stay of discovery is extended through November 4, 2024. The parties shall by that date provide a joint update on the status but not the substance of their settlement talks. SO ORDERED. (Signed by Magistrate Judge Robyn F. Tarnofsky on 9/25/2024) (jca)

Christie R. McGuinness
Phone: [phone]
[e-mail]
www.saul.com

September 24, 2024
Application GRANTED. The stay of discovery is
extended through November 4, 2024. The parties
shall by that date provide a joint update on the
status but not the substance of their settlement
talks.

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

DATED: September 25, 2024
New York, New York

Dear Judge Tarnofsky:
As Your Honor is aware, 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 second update regarding the status of discovery pursuant to the Court’s Case
Management Plan (see ECF No. 82) and, respectfully, request a continued brief stay of discovery
in this matter pending continued settlement discussions.
First, as detailed in the first status update, 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 September 4, 2024, the parties appeared for a Pre-Settlement Conference
Scheduling Call with Judge Ona T. Wang, and on September 26, 2024, the parties will be appearing
for another Pre-Settlement Conference Call to formalize the details of the Settlement Conference,
currently scheduled for October 30, 2024 (see ECF No. 85). After continuing to confer, the Parties
still believe that there is a realistic opportunity to resolve this matter at the October 30, 2024
Settlement Conference. Thus, they respectfully seek a continued stay of discovery pending
completion of the Settlement Conference. The parties seek a continued 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

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New York, NY 10020

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Phone: [phone]

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Fa x : ( 2 1 2 ) 9 8 0 - 7 2 9 2

CALI FORNIA DE LAWARE FLORI DA I LLI NOI S MARYLAND MASSACHUSET TS MI NNESOT A NE W JE RSE Y NE W YORK PE NNSYLVANI A WASHI NGT ON, DC
A DELAWARE LIMITED LIABILITY PARTNERSHIP

September 24, 2024
Page 2
We thank the Court for its attention to this matter and consideration of this request.

Sincerely,

Christie R. McGuinness
CC:
All Counsel Of Record Via ECF.