M. G. et al v. Cuomo et al

Filing 399

ORDER granting 398 Letter Motion for Extension of Time to File. Pre-motion letters regarding summary judgment due 1/6/25. SO ORDERED. (Signed by Judge Cathy Seibel on 11/26/2024) (mml)

Office of the New York State
Attorney General

Letitia James
Attorney General
November 26, 2024

By ECF
Honorable Cathy Seibel
United States District Judge
United States District Court
300 Quarropas Street
White Plains, NY 10601
Re:

Pre-motion letters regarding summary judgment due 1/6/25.

11/26/24

M.G. v. Cuomo, 19-cv-0639 (CS) (AEK)

Joint Request for Extension of Pre-Summary Judgment Letter Deadline

Dear Judge Seibel:
The parties write jointly to provide an update on the status of this matter and to respectfully
request a 30-day extension of the summary judgment pre-motion letter deadline.
As of November 22, 2024, the parties completed fact and expert discovery pursuant to the
case management schedule set by Magistrate Judge Krause (ECF No. 378). 1 The case management
schedule calls for summary judgment pre-motion letters to be filed, pursuant to Your Honor’s
Individual Rules, by Friday, December 6, 2024.
On October 16, 2024, the parties attended a settlement conference with Magistrate Judge
Krause. Following that conference, the parties have continued to discuss the possibility of settlement.
Earlier today, the parties sent Magistrate Judge Krause a joint status report regarding the status of
settlement discussions.
The parties jointly request that the summary judgment pre-motion letter deadline be extended
30 days, to January 6, 2025, in order to give space for the parties to continue to assess the possibility
of a settlement. This is the first request for an extension of the summary judgment pre-motion letter
deadline (although this deadline has previously been moved multiple times as part of global
adjustments to the case management schedule). The requested extension would not affect any other
scheduled dates.
The parties thank Your Honor for your time and attention to this request.

Subject to one request by Defendants for a document (or documents) mentioned in the deposition
testimony of Plaintiffs’ proposed expert Melodie Peet. Defendants followed up in writing on
November 20, 2024, to request the document(s), and Plaintiffs have informed Defendants that they
will respond to Defendants’ request.

1

Litigation Bureau | 28 Liberty Street, New York NY 10005
212-416-8610 | ag.ny.gov

Hon. Cathy Seibel
November 26, 2024

Page 2 of 2

Respectfully submitted,
/s/ Owen T. Conroy
Adam Sansolo
Caroline Wallitt
Gee Won Cha
Owen T. Conroy
Assistant Attorneys General
Counsel for Defendants

DISABILITY RIGHTS NEW YORK
/s/ Elizabeth Woods
Elizabeth Woods
The LEGAL AID SOCIETY
Elena Landriscina
Robert M. Quackenbush
Lauren Nakamura
Veronica Vela
Philip L. Desgranges
PAUL, WEISS, RIFKIND, WHARTON
& GARRISON LLP
Walter Ricciardi
Emily Vance
Ethan Stern
Michael Dauber
Claire Abbadi
Counsel for Plaintiffs