Jacobs v. City of New York ( 2021 )

T. 212.532.1116 F. 212.532.1176 New Jersey Office 576 Main Street, Suite C [ ) Chatham, New Jersey 07928 ELEFTERAKIS JOHN ELEFTERAKIS* ELE FTE RAKIS & NICHOLAS ELEFTERAKIS & PAN EK RAYMOND PANEK | OLIVER R. TOBIAS JEFFREY B. BROMFELD FAIZAN GHAZNAVI GABRIEL P. HARVIS BAREE N. FETT STEPHEN KAHN EVAN M. LA PENNA September 30, 2021 KRISTEN PERRY - CONIGLIARO AIKA DANAYEVA BY ECF MICHAEL INDELICATO . MICHAEL MARRON Honorable Vernon S. Broderick AppLICATION GRANTED , _ DOMINICK MINGIONE United States District J udge $O ORDERED Ale Lone ven LO AGGELIKIE, NIKOLAIDIS Southern District of New York VERNON S. BRODERICK Loulee □□□□□□□ 40 Foley Square U.S.D.J, 10/1/2021 KEYONTE SUTHERLAND New York, New York 10007 “Also Admitted In New Jersey Re: Jacobs, et al. v. City of New York, et al., 18 CV 3275 (VSB) Your Honor: I, along with Gabriel Harvis and Jeffrey Rothman, represent plaintiffs in the above-referenced action. Pursuant to the Court's order dated July 19, 2021, I write on behalf of the parties to provide a status report and to respectfully request that the stay be extended until November 30, 2021. The parties have continued to work cooperatively to move this matter forward. On August 11, 2021, plaintiffs’ out-of-state ballistics expert conducted his forensic evaluation, and anticipates having his report finalized by mid- November. The parties are hopeful that with the benefit of the report, we can then engage in meaningful settlement discussions that may obviate the need for deposition practice. Accordingly, the parties respectfully request that the stay be extended until November 30, 2021, at which time the parties further request that they be permitted to submit a joint status letter advising of our progress. “oo submitted, Baree N. Fett cc: All Counsel