Court Records
CUTI HECKER WANG LLP 305 BROADWAY, SUITE 607 NEW YORK, NY 10007 MARIANN MEIER WANG [Phone Redacted] TO- [Phone Redacted] FAX MWANOIPCHVYLLP.COM January 27, 2020 By ECF Hon. Debra Freeman U.S. District Court for the Southern District of New York Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007.1312 Your Honor: Re: v. Indyke et at., 19-cv-10788 (GHW)(DCF) We represent Plaintiff and write on behalf of all parties. On January 21, 2020, Defendants submitted a pre-motion letter to Judge proposing to file a motion to dismiss. (ECF 16). On January 22, Judge issued an Amended Order Referring Case to Magistrate Judge clarifying that diapositive motions in this matter will be referred to Your Honor for Report & Recommendation. (ECF 17). It is our understanding of Your Honor's Individual Practices that no pm-motion letters are required for motions other than discovery motions, though Plaintiffs counsel is of course happy/prepared to submit one should Your Honor prefer that. Accordingly, we write 1) to seek clarification that Plaintiff need not submit a letter in response to Defendants' January 21 pre-motion letter addressed to Judge and 2) to propose the following briefing schedule for Defendants' motion: Defendants' motion papers to be filed by February 25, 2020; Plaintiffs' opposition papers to be filed by March 17, 2020; Defendants' reply papers to be filed by March 31, 2020. We appreciate Your Honor's attention to this matter. Very truly yours, /s/ Mariann Meier Wang Mariann Meier Wang EFTA02737254 PAGE 2 OF 2 cc: Bennet J. Moskowitz, Counsel for Defendants (by ECF) EFTA02737255