Riverkeeper, Inc. et al v. National Express LLC et al

Filing 17

ORDER granting 16 Letter Motion to Adjourn Conference. Application GRANTED. The Court encourages the parties to consider whether they would like to be referred to the Mediation Program or to Judge Reznik for a Settlement Conference. Parties may make this request at any time. Parties to submit a joint case management plan by May 21, 2025. Defendants to respond to the Complaint by June 4, 2025. The conference scheduled for March 26, 2025 is ADJOURNED to May 28, 2025 at 11:00 a.m. The confer ence will be held remotely by Microsoft Teams. Counsel will receive Microsoft Teams log-in credentials at the email addresses listed on the docket. The public listen-only line may be accessed by dialing: 646-453-4442 | Access Code: 757578439#. SO ORDERED. Initial Conference set for 5/28/2025 at 11:00 AM before Judge Jessica G. L. Clarke. (Signed by Judge Jessica G. L. Clarke on 3/12/2025) (tg)

March 11, 2025

Eric J. Berger

Direct Phone [phone]
Direct Fax
877-434-1068
[e-mail]

VIA ECF
Hon. Jessica G.L. Clarke
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 10007-1312
Re:

Riverkeeper, Inc. and Save the Sound, Inc. v. National Express LLC and White
Plains Bus Co., Inc.
Docket No.: 7:24-cv-09676-JGLC

Dear Judge Clarke:
This firm was recently retained to represent defendants, National Express LLC and White Plains
Bus Co., Inc., in the above-captioned matter. I and my colleague, Meredith Renquin, Esq., noticed
our appearances this past Friday, March 7, 2025.
Please allow this letter to serve as an application for a 60-day adjournment of the (i) March 19,
2025 deadline to submit a proposed Civil Case Management Plan and Scheduling Order and joint
letter; (ii) March 26, 2025 Initial Pretrial Conference; and (iii) April 4, 2025 deadline to respond
to the Complaint.
In addition to requiring some additional time to get up to speed on this environmental matter, Ms.
Renquin and I have had discussions with plaintiffs’ counsel, Reed W. Super, Esq., regarding the
potential for fully resolving the matter before engaging in formal discovery and any responsive
pleading or motion practice. As such, all parties agree that a 60-day adjournment will be beneficial
in that it will allow the parties, their counsel and environmental consultants to focus their resources
on settlement.
At the end of the 60-day adjournment, the parties would report to the Court on the prospects of
reaching a complete settlement expeditiously, and if not, will submit a proposed Civil Case
Management Plan and Scheduling Order and joint letter that has been more thoroughly informed
by their substantive discussions.
Thank you for your consideration.

3 WTC

175 Greenwich Street

212.509.9400

800.437.7040

55th Floor

New York, NY 10007

212.509.9492 Fax

cozen.com

Hon. Jessica G.L. Clarke
March 11, 2025
Page 2

______________________________________

Respectfully submitted,
COZEN O'CONNOR

By:

Eric J. Berger

cc:

All Counsel via ECF

Application GRANTED. The Court
encourages the parties to consider whether
they would like to be referred to the
Mediation Program or to Judge Reznik for a
Settlement Conference. Parties may make
this request at any time. Parties to submit a
joint case management plan by May 21,
2025. Defendants to respond to the
Complaint by June 4, 2025. The conference
scheduled for March 26, 2025 is
ADJOURNED to May 28, 2025 at 11:00
a.m. The conference will be held remotely
by Microsoft Teams. Counsel will receive
Microsoft Teams log-in credentials at the
email addresses listed on the docket. The
public listen-only line may be accessed by
dialing: 646-453-4442 | Access Code:
757578439#.
SO ORDERED.

JESSICA G. L. CLARKE
United States District Judge
Dated: March 12, 2025
New York, New York