Jacobs v. City of New York

NCW TOR, NOW TOR □□ T. 212.532.1116 F. 212.532.1176 New Jersey Office Main Street, Suite C Chatham, New Jersey 07928 ELEFTERAKIS JOHN ELEFTERAKIS* ELEFTERAKIS NICHOLAS ELEFTERAKIS PANEK RAYMOND PANEK [ OLIVER R. TOBIAS JEFFREY B. BROMFELD FAIZAN GHAZNAVI GABRIEL P. HARVIS BAREE N. FETT STEPHEN KAHN EVAN M. LA PENNA September 30, 2020 KRISTEN PERRY - CONIGLIARO AIKA DANAYEVA BY ECF ARIANA ELEFTERAKIS —__ APPLICATION GRAN MICHAEL INDELICATO Honorable Vernon S. Broderick 4 A LD J MICHAEL MARRON United § Distri q SO ORDERED A &-. Dt bh DOMINICK MINGIONE nited States District € oe MARK NEWMAN es Judg VERNON 8. BRODERICK AGGELIKI E. NIKOLAIDIS Southern District of New York USD, 10/2/2020 JOSEPH PERRY eepsenite MARIE LOUISE PRIOLO * Foley Square KEYONTE SUTHERLAND New York, New York 10007 WAYNE WATTLEY “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 June 29, 2020, I write on behalf of the parties to provide a status report and to respectfully request that the stay be extended until November 30, 2020.

The parties have continued to work cooperatively to exchange documents and P P y material so that plaintiffs’ out-of-state ballistics expert may conduct his forensic evaluation in New York. Unfortunately given the delays caused by the Covid-19 pandemic, including that plaintiffs’ expert is traveling from out-of-state, our progress has been slower than anticipated. We are hopeful, however, that the ballistics evaluation can be completed within the next sixty days.

Accordingly, the parties respectfully request that the stay be extended until November 30, 2020, at which time the parties further request that they be permitted to > , P q ybep submit a joint status letter advising of our progress.

Respectfully submitted, Baree N. Fett cc: All Counsel