WIL FLLW Stephanie Panousieris | [email protected] December 2, 2024 Via ECF Hon. Kenneth M. Karas United States District Judge Federal Building and United States Courthouse 300 Quarropas St. White Plains, NY 10601-4150 Re: Notice of Appearance — Cooper v. Greene Haven, 24 cv 01128 Your Honor: This office has been retained by Plaintiff Tyrone Cooper to represent him in the above-captioned We write to respectfully request that the Court’s June 10, 2024 Valentin Order (Dkt. □□ be kept in place to assist the parties in identifying the proper Defendants in this action. Mr. Cooper filed this case, pro se, on February 12, 2024 (Dkt. 1), seeking damages pursuant to

for violations of his constitutional and statutory rights arising from the cutting of his dreadlocks during reception into the New York State Department of Corrections and Community Supervision (““DOCCS”). Plaintiff, who is Rastafarian, had a signed Court order prohibiting DOCCS from cutting his hair. Staff ignored this order, and its own internal written policies, and forced Plaintiff to have his head shaved on or about November 28, 2023. Plaintiff filed this suit against the facility in which his hair was cut, Green Haven, and on June 10, 2024, Your Honor entered an order dismissing this improper party and directing the Office of the Attorney General (““AG”) to investigate and identify the involved DOCCS staff members pursuant to Valentin v. Dinkins,

(2d Cir. 1997). While Plaintiff will no longer be proceeding pro se, we believe that leaving the Valentin order in place will expedite joinder of the proper individual defendants in this action. Because our office was retained post-filing, we are in the early stages of gathering documents and information pursuant to our Rule 11 duties. In order to keep this case moving and avoid any unnecessary delay, we respectfully request that the Court keep the Valentin Order in place, but direct the AG’s office to communicate the results of their investigation directly to undersigned counsel, at which point we will promptly file and serve an amended complaint on Mr. Cooper’s behalf. We thank the Court for its time and consideration of this request. Sincerely This application makes eminent sense and is 7 therefore granted. Hi So Ordered. Stephanie Panousieris Attorney for Plaintiff 12/3/24

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