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THE CiTy oF NEW YORK HON. SYLVIA O. HINDS-RADIX LAW DEPARTMENT MARY JANE ANDERSON Corporation Counsel 100 CHURCH STREET Assistant Sey □ cu NEW YORK, N.Y. 10007 Fax: (212) 356-3509 [email protected] GRANTED. SO ORDERED. VIA E.C.F. □ Honorable Jennifer E. Willis &. Willo United States District Court vay: * Jemnifer E. Willis Southern District of New York . . United States Magistrate Judge 40 Foley Square New York, New York 10007 eNOS NENT September 7, 2023 Re: Christopher Chabrier v. Martinez, et al., 22-CV-6239 (GHW) (JW) Your Honor: I am an Assistant Corporation Counsel in the New York City Law Department and the attorney representing defendants the City of New York, Officer Martinez, and Captain Young in the above referenced matter. Defendants write to respectfully request to be relieved of the obligation to respond to the Court’s Valentin Order. Plaintiffs position is that the Valentin Order no longer applies because he is now represented by counsel. By way of background, on August 12, 2022, the Court ordered this Office to identify: (1) the three AMKC John Doe correction officers who allegedly failed to protect Plaintiff from assaults on May 12 and 15, 2021 at Dorm 2 Upper of AMKC; (2) the AMKC John Doe medical staff members who provided medical care to Plaintiff after the May 15, 2021 assault; (3) the AMKC John Doe correction officers, who were allegedly deliberately indifferent to Plaintiff's serious medical condition after the May 15, 2021 assault; (4) the VCBC John Doe correction officers, who were allegedly deliberately indifferent to Plaintiff's medical condition from May 18 to 22, 2022[']; and (5) the VCBC John Doe medical staff members who provided medical care to Plaintiff from May 18 to May 22, 2021. (See ECF No. 7.) While we have been able to comply with parts two, three, and five of the Valentin Order, the remaining individuals have yet to be identified: (1) two of the AMKC John Doe correction officers from May 12 and 15, 2021 and (2) the VCBC John Doe correction officers from May 18 to 22, 2021.

' As noted in the Office’s October 11, 2022 Letter, although the Court’s Order states that the alleged incident occurred in 2022, based on a review of the Complaint and documents in this Office’s possession at this time, upon information and belief, the alleged incident occurred in 2021. (See ECF No. 13.)

On July 28, 2023, Defendants requested an extension of time to respond to the Court’s Valentin Order. On August 1, 2023, the Court granted Defendants’ request, extending the time to respond to the Valentin Order until August 29, 2023. Since the filing Defendants’ last letter, we have produced responses to Local Civil Rule 33.2 discovery requests to Plaintiff. Furthermore, and of note, since the filing of Defendants’ last letter, Plaintiff obtained counsel. We have met and conferred with Plaintiff’s counsel and will work to appropriately produce any additional discovery in this matter that can assist in identifying who Plaintiff seeks to sue. However, since Valentin v. Dinkins applies to actions “brought by pro se litigants,” Defendants respectfully request to be relieved of the Court’s Valentin Order.

. Defendants thank the Court for its time and consideration herein. Respectfully submitted, __/s/ Mary Jane Anderson . Mary Jane Anderson Assistant Corporation Counsel Special Federal Litigation Division CC: VIA E.C.F Caner Demirayak [email protected]