Monroe v. Gerbing et al

Filing 173

ORDER granting 168 Letter Motion for Conference; granting 168 Letter Motion to Stay. Granted. The revised discovery schedule, including the stay, is approved. SO ORDERED. (Signed by Judge Kenneth M. Karas on 9/10/2020) (jca)

Case 7:16-cv-02818-KMK Document 173 Filed 09/10/20 Page 1 of 2
Case 7:16-cv-02818-KMK Document 168 Filed 09/04/20 Page 1 of 2

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STATE OF NEW YORK
OFFICE OF THE ATTORNEY GENERAL
LETITIA JAMES

DIVISION OF ST ATE COUNSEL

ATTORNEY GENERAL

LITIGATION BUREAU

Writer's Direct Dial: [phone]

September 4, 2020

VIAECF
Honorable Kenneth M. Karas
United States District Court
Southern District of New York
300 Quarropas Street
White Plains, NY 10601
Re: Monroe v. Gerbing, 16-cv-2818 (KMK)
Dear Judge Karas:
This Office represents Defendants in the above-captioned case. I write on behalf of all
parties to jointly request a settlement conference before a Magistrate Judge as soon as the Court is
able, preferably within the next 4 weeks. The parties have been negotiating, and believe that a
settlement conference could be beneficial and helpful in their attempt to settle this matter.
Separately, the parties request a stay of discovery pending the outcome of the settlement
conference. If the case does not settle, the parties are prepared to meet the deadlines in the existing
scheduling order within 6-11 weeks after the conclusion of the settlement reference, as stated
below.
The parties note that there is a discrepancy in the deposition deadline. The June 3, 2020
docket entry notes that the deposition deadline is October 28, 2020, while the underlying document
provides a different date-September 28, 2020--as the deadline. The parties request that, in the
event the Court does not stay discovery pending the outcome of the settlement conference, the
Court endorse the October 28, 2020 deadline for depositions.

Deadline for the completion of depositions

September 28,
2020 I
October 28, 2020

28 Liberty Street, New York, New York 10005 • Tel.: [phone] • Fax: [phone]
www.ag.ny.gov

45 Days after the
Magistrate Judge
reports that the
parties' attempts to
settle the case were
unsuccessful

(Not For Service of Papers)

Case 7:16-cv-02818-KMK Document 173 Filed 09/10/20 Page 2 of 2
Case 7:16-cv-02818-KMK Document 168 Filed 09/04/20 Page 2 of 2

Deadline for the disclosure of Plaintiff's experts,
including reports, production of underlying
documents, and depositions

September 28,
2020

Deadline for serving requests to admit

October 12, 2020

Deadline for pre-motion letter(s)

October 29, 2020

Deadline for the disclosure of Defendants' experts,
including reports, production of underlying
documents, and depositions

October 28, 2020

Deadline for response to pre-motion letter(s)

November 5, 2020

45 Days after the
Magistrate Judge
reports that the
parties' attempts to
settle the case were
unsuccessful
60 Days after the
Magistrate Judge
reports that the
parties' attempts to
settle the case were
unsuccessful
70 Days after the
Magistrate Judge
reports that the
parties' attempts to
settle the case were
unsuccessful
70 Days after the
Magistrate Judge
reports that the
parties' attempts to
settle the case were
unsuccessful
80 Days after the
Magistrate Judge
reports that the
parties' attempts to
settle the case were
unsuccessful

We thank the Court for its attention to this matter.
Respectfully submitted,
Isl Amanda Yoon
Amanda Yoon
Assistant Attorney General
Amanda.Y [e-mail]
cc: Nimra Azrni, Esq.
Victoria Whitney, Esq.
Mary Bauer, Esq.
Counsel for Plaintiff(via ECF)

Granted. The revised discovery schedule, including
the stay, is approved.

~~
9/10/20

28 Liberty Street, New York, New York 10005 • Tel.: [phone] • Fax: [phone]
www.ag.ny.gov

(Not

For Service of Papers)