& ~ 2 T7 State-Steeets | ATTORNEYS AT LAW - BOL □ Bay + 39th Flner |; EVAN TORGAN ae 8 pa ; NewYork, NY1000¢ EDWARD T: COOPER RF) HOls #LCHELL K AARON Achieving,a. better firture for-sur cllents Office 212-29229500 —- Paxt 212-232/2509 JONATHAN TABAR a BRENDAN BROWN □□□□□□□□□□□□□□□□□□□□□ eee cane OfCeaneel

April 14, 2025 Via EGF & EMAIL Hon. Payl A. Bigehnayer United States District Judge Southern District of New York □ $00.Pearl Street New Yorks, New York‘10007 □□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□ Re; Li Goodwiny. Oren Alexander, 25-CV-2247 (PAE) Joiit Request'to Stay Proceedings. Your Honor:

__- We write jointly on behalf:of all parties-putsuanit to the Court's Order dated Mareh 19, 2025, which witeoted the patties 16 submits Civil Case ManapementPlan and Scheduling Order, as well as a joitit létter, in advance of the: initial protrial conference currently stheduled for April 16, 2025, at 2:06 pin, By way of background, thisunatierinvalves a cause of action vindeé thé Victims of Gender Motivated Violence Protedtion Law (“VGMVPLM), N.Y.C. Admin. Code § 10-1401 er sey. Plaintiff alleges that. she was sumeptitiously drugged and. subsequently saped affer meeting Deferidant Oren Alexander, (“Defendant”) ata Gotham Magazine party on February 13; 2011, Defendant, denies these allegations and contends thet the action is tithe-batted atid preempted by’New Yoik State's Child Vistins Act (“CVA") atid Adult Survivors Act (CASA). □ Defendant also andlipates filing a motion pursuattt to Federal Rule of Civil Procedure: 130) serkirig disinissal of the Complaint with prejudice. Ty light of the evolving legal landscape xelevant fo tho claims at issue in. this maiter, the parfies tespoctfully request that. the Court atay the proceedings for 4 period Gf six (6) tnonths, Specifically, we ask that the Court adopt the stime approach it recently employed in Willett. Alexandév,. No, 24-CV-05672 (NRB) and Laura.Byck v, Tal Alesaniler, ef al, No. 25-CV-2119 (NRB), aiid stay this dition pending develuprients it related appellate proceedings.

| TORGAN, COOPER + AARON, BC. | As Your Honor niay- be aware, two oases duiténtly pending before the United States Court of Appesils for the Second Circuit—Parker v. Alexander, 'No. 24 Civ. 4813 (LAK),

(S,D.N-Y. Jan. 22, 2025), and Doe.v. Black, No, 23 Civ, 6418 (JGLG),

(S.D.N-Y., Sept, 27, 2024)-—taise substantially similar legal questions fo those presented by Defendants in this ratter, The Second Circuit’s résolution of those appeals is likely to be dispositive or, at minimum, instructive with respect to the central issues in this case, □ Accordingly, in the interest of judicial economy and to avoid potentially uonevessary motion practice; the parties respectfully request that the Court enter an informal stay of all déaddlines and proceedizigs in this matter for apetiod of at least six months, of until further direction is received from the Court following resolution or clarification from the Second Circuit, We tharik the Court for its attention to this matter and are availdble to provide any additional information the Court may find helpful. □

Respectfully subrnitted,

Raat ~~ TORGAN COOPER & AARON, P.C, 17 State Street, 39" Floor New York, New York 10004 Tel 212-232-2500 Attorney(s) for Plaintiff Ti Goodwin

Jason ghia LAW OEICES OF JASON GOLDMAN 275 Mddison Avenue, 35" Floor New York, New York 10016 . Tél: 212-466-6617 Counsel for Defendant Oren Alexander GRANTED. This case is hereby stayed pending the Second Circuit decisions in Parker v. Alexander, No. 24 Civ. 4813 (LAK),

(S.D.N.Y. Jan 22, 2025), and Doe v. Black, No. 23 Civ. 6418 (JGLC),

(S.D.N.Y. Sept. 27, 2024). The parties are to jointly file a status update no later than two weeks after the date of each decision. SO ORDERED. | in . PUVA 185 8 np PUIG Y PAUL A. ENGELMAYER United States-Bistrict dudge 14 O0O906