Stephanie McCaffrey v. New York City Police Department

BINS: Rese THE CITY OF NEW YORK Muriel Goode-T, LAW DEPARTMENT A HA Conporation Counsel 100 CHURCH STREET aoe eS □□□□ Couns NEW YORK, NY 10007 Labor & Employment Law Divisio (212) 356-089 [email protected] November 12, 2025 Via ECF Honorable Judge Jennifer L. Rochon United States District Judge United States District Court Southern District of New York Pearl Street, Courtroom 20B New York, New York 10007 Re: Stephanie MCCaffrey v. New York City Police Department Civil Action No.: 25-cv-06528 (JLR) Dear Judge Rochon: I am an Assistant Corporation Counsel in the Office of Muriel Goode-Trufant, Corporation Counsel of the City of New York, assigned to represent Defendant in the above- referenced action. I write to apologize for the delay in submitting the proposed Case Management Plan as directed by the Court. The omission was inadvertent, and I sincerely regret any inconvenience caused to the Court.

At this time, with the consent of Plaintiff's counsel, Defendant respectfully requests that discovery be stayed pending the resolution of Defendant’s motion to dismiss. The motion was filed on November 9, 2025, and if granted, may dispose of or significantly narrow the issues in this case. A stay would therefore conserve judicial and party resources.

We thank the Court for its consideration of this request.

GRANTED. A court may, on a showing of "good cause," stay discovery during the of a motion to dismiss. See, e.g., Republic of Turkey v. Christie's, Inc., 316 F. Supp. 3d Respectfully Submitted, (S.D.N.Y. 2018). However, the filing of a motion to dismiss does not itself constitute and courts have considerable discretion in determining whether a stay is warranted. v. Lebanese Canadian Bank, SAL, No. 08-cv-7253 (GBD) (KHP), 2022 WL 2541081, at July 7, 2022). In exercising this discretion, courts consider: "(1) [the] breadth of Sonya Gidumal Chazin ry sought, (2) any prejudice that would result, and (3) the strength of the motion." Hong Assistant Corporation Counsel Ltd. (Singapore) v. Pinnacle Performance Ltd., 297 F.R.D. 69, 72 (S.D.N.Y. 2013). The of the motion" factor contemplates whether the party seeking the stay has "substantial for dismissal," or whether "the plaintiff's claim is unmeritorious." Jd. (citations omitted). Dated: November x. “ □ the consent of the parties, the likely breadth of discovery to be sought, and the possibility ow NOTE os O ORDERED decision on the motion to dismiss will narrow the claims at issue, the Court concludes that □ it warranted to stay discovery pending a decision on the motion to dismiss. Accordingly, CL peber iB ch bo