IN RE: NEW YORK CITY POLICING DURING SUMMER 2020 DEMONSTRATIONS

WASE CUTUVUOIULS UNI LUUUTTICIN GOS FURU USI eOlreo Faye 4 □□ Case 1:21-cv-00533-CM Document 160 Filed 04/28/23 Page 1 of 3 ” Tuspe spss | DocuMENT \ ELECTRONICALLY FILP™ ape ae, aes Hon. Colleen McMahon] noc 4: United States District Cpurt _ = C | | 7p.

Southern District of Ne yA iE FILED: ———— | 909 York 500 Pearl Street SS l Vf New York, New York 10007 O | { Hon. Gabriel W. Gorenstein pt bt United States District Court fi Ze Southern District of New yw York 500 Pearl Street (| New York, New York 10007 2 od, | ie x rerAE CTA SP By Electronic Filing ry ba Ka ak pide © / Re: = In re: New York City Policing During Summer 2020 Demonstrations, WV.

No. 20 Civ. 8924 (CM) oS S | □ This filing is related to: Sop et al v. City Of New York et al.

No. 21-cv-00533 (CM) (GWG) Your Honors: As counsel for the Plaintiffs and putative class in the Sow ef al. . v. City Of New York et al. case, we write jointly with Defendants tq inform the Court that the parties have reached a proposed See □□□ ee including all claims for the proposed class in the Sow case. As the Court is aware, this matter was broght as a putative class action for declaratory relief and monetary damages. The proposed class will consist of people arrested between May 28, 2020 and June 4, 2020 at specific protest locations in New York City.

The parties have agreed to sevéral terms including the amounts for claims awards for putative class members, and to stay further discovery pending submission of a settlement stipulation for the Court’s approval. The parties) also intend to attempt to separately resolve Plaintiffs’ reasonable costs and attorneys’ fees. To be clear, these settlement terms, and the agreed- upon stay of discovery, cover only the Sow case.

The parties have significant work to do to finalize this class action settlement and are working together in good faith to complete these asks. This include negotiating the additional terms of the settlement, preparing a full stipulation of settlement, a motion for preliminary approval of the proposed settlement, appointment of a clasS\administrator, and certification of the class pursuant to Fed. R. Civ. P. 23, and proposed class notices\and claim forms, among other things. As such, the parties respectfully request until June 30, 2023, tq submit the motion along with proposed class settlement documents.

Cohen&Green PL.L.C. - 1639 Centre Street, Suite 216 - Ridgewood, New York - 11385 + t: (929) 888.9480 - £: (929) 888.9457 - FemmeLaw.com 4. CUTCVUOILS UNI VUCUINENL FHeCU USI eolreoG Faye 4 Ulso Case 1:21-cv-00533-CM Document 160 Filed 04/28/23 Page 2 of 3 By Court Order dated February 10, 2023, the Court reset the briefing schedule for motions for class certification. (See Dkt. No. 849). Pursuant to the subsequent court-endorsed Order on April 30, 2023, Plaintiffs must move to certify their class by April 30, 2023. (See Dkt. No. 917). In light of the settlement in principle and the parties’ continued negotiations, Plaintiffs hope to be able to seek certification without opposition as a result of the settlement. As such, we respectfully request that the court stay any such motion practice sine die, to allow the parties to finalize the settlement of this matter and submit the settlement documents for court approval.

The parties thank for the Court for its consideration of these two requests.

Respectfully submitted, BELDOCK LEVINE & HOFFMAN LLP GIDEON ORION OLIVER By: 277 Broadway, Suite 1501 Jonathan C. Moore eG aes 10007 David B. Rankin Oe eee Frama Gheeit f: 646-349-2914 Ri war heart [email protected] Deema Azizi Rebecca Pattiz Katherine “Q” Adams COHEN&GREEN P.L.L.C. Regina Powers C0, □□□ Park Avenue, PH/26th Floor New York, New York 10016 t: 212-490-0400 e: [email protected] Elena L. Cohen [email protected] J. Remy Green [email protected] Jessica Massimi [email protected] [email protected] 1639 Centre Street, Suite 216 [email protected] Ridgewood (Queens), NY 11385 [email protected] t: (929) 888-9480 [email protected] f: (929) 888-9457 ! Page 2 of 3 Cohen&Green P.L.L.C. + 1639 Centre Street, Suite 216 « Ridgewood, New York - 11385 + t: (929) 888.9480 . f: (929) 888.9457 - FemmeLaw.com Case 1.2U-CV-Us92<4-OCNMl VOCUMENT YOU FHEQ U4iZ0/25 FAgE SOLS Case 1:21-cv-00533-CM Document 160 Filed 04/28/23 Page 3 of 3 WYLIE STECKLOW PLLC By: Wylie Stecklow Wylie Stecklow PLLC Carnegie Hall Tower 152 W. 57" Street, 8" Floor NYC NY 10019 t: 212 566 8000 [email protected] INF j Page 3 of 3 Cohen&Green P.L.L.C. - 1639 Centre Street, Suite 216 - Ridgewood, New York - 11385 + t: (929) 888.9480 - £: (929) 888.9457 - FemmeLaw.com