Legal Correspondence / Court Order - 019

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Extraction Summary

5

People

2

Organizations

2

Locations

2

Events

2

Relationships

1

Quotes

Document Information

Type: Legal correspondence / court order

File Size: 317 KB

Summary

A letter from plaintiff's attorney Mariann Meier Wang to Magistrate Judge Debra Freeman in the case of Davies v. Indyke et al., dated January 27, 2020. The letter proposes a briefing schedule for a motion to dismiss. Judge Freeman endorsed the letter with a handwritten order on January 28, 2020, directing counsel to provide an update on settlement discussions before the court sets a briefing schedule.

People (5)

Name	Role	Context
Teala Davies	Plaintiff	Represented by Mariann Meier Wang in lawsuit against Indyke et al.
Mariann Meier Wang	Attorney	Partner at Cuti Hecker Wang LLP representing Plaintiff Teala Davies
Debra Freeman	United States Magistrate Judge	Judge overseeing the case to whom the letter is addressed and who issued the handwritten order
Darren Indyke	Defendant	Named defendant in the case caption (Davies v. Indyke et al.)
Gregory H. Woods	Judge	District Judge (referred to as Judge Woods) who referred the case to Magistrate Judge Freeman

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 where the case is filed

Timeline (2 events)

2020-01-22

Judge Woods issued an Amended Order Referring Case to Magistrate Judge.

SDNY

Judge Woods Debra Freeman

View

2020-01-28

Judge Debra Freeman issues an order directing counsel to submit an update regarding settlement discussions before setting a briefing schedule.

SDNY

Debra Freeman Counsel

View

Locations (2)

Location	Context
305 Broadway, Suite 607, New York, NY 10007	Address of Cuti Hecker Wang LLP
500 Pearl St., New York, NY 10007-1312	Address of United States Courthouse

Relationships (2)

Teala Davies → Attorney-Client → Mariann Meier Wang

We represent Plaintiff Teala Davies

Teala Davies → Legal Adversary → Darren Indyke

Case caption: Davies v. Indyke et al.

Key Quotes (1)

"Before this Court sets a briefing schedule for a motion to dismiss, counsel are directed to submit an update regarding their settlement discussions, specifically addressing the potential for this action being resolved without the need for motion practice."

Source

019.pdf

Quote #1

Full Extracted Text

Complete text extracted from the document (2,095 characters)

Case 1:19-cv-10788-GHW-DCF Document 19 Filed 01/28/20 Page 1 of 1
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

USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 1/28/2020

[Handwritten Note/Order]:
Before this Court sets a briefing schedule for a motion to dismiss, counsel are directed to submit an update regarding their settlement discussions, specifically addressing the potential for this action being resolved without the need for motion practice.

SO ORDERED: DATE: 1/28/2020
/s/ Debra Freeman
DEBRA FREEMAN
UNITED STATES MAGISTRATE JUDGE

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

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