018.pdf
60.7 KB
Extraction Summary
6
People
2
Organizations
2
Locations
5
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal correspondence
File Size:
60.7 KB
Summary
A letter dated January 27, 2020, from attorney Mariann Meier Wang to Magistrate Judge Debra Freeman regarding the case Davies v. Indyke et al. The letter seeks clarification on procedural requirements following the referral of the case and proposes a briefing schedule for the Defendants' motion to dismiss, with dates ranging from February to March 2020. It references prior court filings from January 21 and January 22, 2020.
People (6)
| Name | Role | Context |
|---|---|---|
| Mariann Meier Wang | Attorney |
Sender; Partner at Cuti Hecker Wang LLP; represents Plaintiff Teala Davies.
|
| Teala Davies | Plaintiff |
Client of Mariann Meier Wang in Davies v. Indyke et al.
|
| Debra Freeman | Magistrate Judge |
Recipient of the letter; U.S. District Court for the Southern District of New York.
|
| Gregory H. Woods | Judge |
Referenced as 'Judge Woods'; issued an Amended Order Referring Case.
|
| Indyke | Defendant |
Named in case title 'Davies v. Indyke et al.'.
|
| Bennet J. Moskowitz | Attorney |
Counsel for Defendants; copied (cc) on the letter.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Cuti Hecker Wang LLP |
Law firm representing the Plaintiff.
|
|
| U.S. District Court for the Southern District of New York |
Court handling the case.
|
Timeline (5 events)
2020-01-21
Defendants submitted a pre-motion letter to Judge Woods proposing to file a motion to dismiss.
U.S. District Court SDNY
Defendants
Judge Woods
2020-01-22
Judge Woods issued an Amended Order Referring Case to Magistrate Judge.
U.S. District Court SDNY
Judge Woods
2020-02-25
Proposed deadline for Defendants' motion papers to be filed.
U.S. District Court SDNY
Defendants
2020-03-17
Proposed deadline for Plaintiffs' opposition papers to be filed.
U.S. District Court SDNY
Plaintiffs
2020-03-31
Proposed deadline for Defendants' reply papers to be filed.
U.S. District Court SDNY
Defendants
Locations (2)
| Location | Context |
|---|---|
|
Address of Cuti Hecker Wang LLP.
|
|
|
Address of the U.S. District Court.
|
Relationships (2)
We represent Plaintiff Teala Davies
Counsel for Defendants
Key Quotes (3)
"We represent Plaintiff Teala Davies, and write on behalf of all parties."Source
018.pdf
Quote #1
"It is our understanding of Your Honor’s Individual Practices that no pre-motion letters are required for motions other than discovery motions"Source
018.pdf
Quote #2
"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 Woods, and 2) to propose the following briefing schedule for Defendants’ motion"Source
018.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (1,655 characters)
CUTI HECKER WANG LLP 305 BROADWAY, SUITE 607
NEW YORK, NY 10007
MARIANN MEIER WANG
212.620.2603 TEL
212.620.2613 FAX
MWANG@CHWLLP.COM
January 27, 2020
By ECF
Hon. Debra Freeman
U.S. District Court for the Southern District of New York
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 10007-1312
Re: Davies v. Indyke et al., 19-cv-10788 (GHW)(DCF)
Your Honor:
We represent Plaintiff Teala Davies, and write on behalf of all parties.
On January 21, 2020, Defendants submitted a pre-motion letter to
Judge Woods proposing to file a motion to dismiss. (ECF 16). On January 22,
Judge Woods issued an Amended Order Referring Case to Magistrate Judge
clarifying that dispositive 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 pre-motion letters are required for motions other than
discovery motions, though Plaintiff’s 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 Woods, 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
NEW YORK, NY 10007
MARIANN MEIER WANG
212.620.2603 TEL
212.620.2613 FAX
MWANG@CHWLLP.COM
January 27, 2020
By ECF
Hon. Debra Freeman
U.S. District Court for the Southern District of New York
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 10007-1312
Re: Davies v. Indyke et al., 19-cv-10788 (GHW)(DCF)
Your Honor:
We represent Plaintiff Teala Davies, and write on behalf of all parties.
On January 21, 2020, Defendants submitted a pre-motion letter to
Judge Woods proposing to file a motion to dismiss. (ECF 16). On January 22,
Judge Woods issued an Amended Order Referring Case to Magistrate Judge
clarifying that dispositive 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 pre-motion letters are required for motions other than
discovery motions, though Plaintiff’s 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 Woods, 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
PAGE 2 OF 2
cc: Bennet J. Moskowitz, Counsel for Defendants (by ECF)
cc: Bennet J. Moskowitz, Counsel for Defendants (by ECF)
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