CUTI HECKER WANG LLP

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MARIANN MEIER WANG
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MWANG@CHWLLP.COM

January 27, 2020

By ECF

Hon. Debra Freeman
U.S. District Court for the Southern District of New York
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 10007-1312

Re: Davies v. Indyke et al., 19-cv-10788 (GHW)(DCF)

Your Honor:

We represent Plaintiff Teala Davies, and write on behalf of all parties.

On January 21, 2020, Defendants submitted a pre-motion letter to Judge Woods proposing to file a motion to dismiss. (ECF 16). On January 22, Judge Woods issued an Amended Order Referring Case to Magistrate Judge clarifying that dispositive motions in this matter will be referred to Your Honor for Report & Recommendation. (ECF 17). It is our understanding of Your Honor’s Individual Practices that no pre-motion letters are required for motions other than discovery motions, though Plaintiff’s counsel is of course happy/prepared to submit one should Your Honor prefer that.

Accordingly, we write 1) to seek clarification that Plaintiff need not submit a letter in response to Defendants’ January 21 pre-motion letter addressed to Judge Woods, and 2) to propose the following briefing schedule for Defendants’ motion:

- Defendants’ motion papers to be filed by February 25, 2020;

- Plaintiffs’ opposition papers to be filed by March 17, 2020;

- Defendants’ reply papers to be filed by March 31, 2020.

We appreciate Your Honor’s attention to this matter.

Very truly yours,
/s/ Mariann Meier Wang
Mariann Meier Wang

PAGE 2 OF 2

cc: Bennet J. Moskowitz, Counsel for Defendants (by ECF)
court-records/Davies v. Indyke, No. 119-cv-10788 (S.D.N.Y. 2019)/018.pdf
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