Ramos v. Apple Inc.

Filing 76

ORDER granting 75 Letter Motion to Stay re: 75 LETTER MOTION to Stay addressed to Judge Nelson Stephen Roman from Jeffrey W. Brecher, Esq. dated April 22, 2024. LETTER MOTION for Extension of Time to File Response/Reply addressed to Judge Nelson Stephen Roman from Jeffrey W. Brecher, Esq. dated April 22, 2024. ; granting 75 Letter Motion for Extension of Time to File Response/Reply re 75 LETTER MOTION to Stay addressed to Judge Nelson Ste phen Roman from Jeffrey W. Brecher, Esq. dated April 22, 2024. LETTER MOTION for Extension of Time to File Response/Reply addressed to Judge Nelson Stephen Roman from Jeffrey W. Brecher, Esq. dated April 22, 2024. The Court grants pa rties' requested extension to the motion to dismiss briefing schedule. Plaintiffs' opposition is now due May 29, 2024, and Defendant's reply papers are now due June 20, 2024. The parties are directed to seek a stay of discovery from Magistrate Judge McCarthy. The Clerk of Court is kindly directed to terminate the motion at ECF No. 75. ( Responses due by 5/29/2024, Replies due by 6/20/2024.). (Signed by Judge Nelson Stephen Roman on 5/6/2024) (ate)

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April 22, 2024
VIA ECF
05/06/2024
Judge Román
Federal Building and United States Courthouse
300 Quarropas Street
White Plains, NY 10601-4150
Re:

Raven Ramos, et al. v. Apple, Inc.
Case No.: 22-cv-02761

Dear Judge Román:
We represent the Defendant, Apple Inc. Together with counsel for Plaintiffs, the parties write jointly
to request: (1) an extension of the parties’ motion to dismiss briefing schedule, and (2) a stay of
discovery, for 45 days, so the parties can attend a mediation to potentially resolve this matter. The parties
have agreed to a mediator and have scheduled a mediation for May 22, 2024. An extended briefing
schedule and short stay of discovery will permit the parties to potentially avoid unnecessary litigation
and associated costs. Accordingly, the parties respectfully suggest the below updated briefing schedule:




Opposition to Motion to Dismiss: May 29, 2024 (currently May 1, 2024)
Reply in Support of Motion to Dismiss: June 20, 2024 (currently May 16, 2024)

The parties further propose that on or before June 3, 2024 they will submit a revised discovery
plan to Magistrate Judge McCarthy. We previously directed this request to Magistrate Judge McCarthy,
but she advised the parties should direct this request to Your Honor.
Thank you for your attention to this matter.
Respectfully submitted,
s/ Jeffrey W. Brecher

4865-2572-9976, v. 1

JEFFREY W. BRECHER, ESQ.
The Court grants parties' requested extension to the motion to dismiss briefing schedule.
Plaintiffs' opposition is now due May 29, 2024, and Defendant's reply papers are now due June
20, 2024. The parties are directed to seek a stay of discovery from Magistrate Judge McCarthy.
The Clerk of Court is kindly directed to terminate the motion at ECF No. 75.

Dated: May 6, 2024
White Plains, NY