Opinion
20-cv-10033-LAK
07-29-2022
Feliciano, Madline v. The City of New York, et al.,
HON. LEWIS A KAPLAN, U.S. DISTRICT COURT JUDGE
Your Honor:
My office represents Plaintiff Madeline Feliciano, Guardian of Nicholas Feliciano, in the above-referenced matter. I write pursuant to the Court's June 15, 2022 Order (ECF No. 63) for a status report proposing a schedule for further proceedings or stating if there is a disagreement on how to proceed. As the Court is aware, Defendants City of New York and Tasha Lambre have requested a stay in this matter due to a pending criminal investigation regarding this incident. The request was made upon consent of Plaintiff without prejudice to further requests for a stay or opposition to such a further request by any party and granted by the Court.
On behalf of Plaintiff and Defendant City of New York, we respectfully request a brief extension of the stay. Plaintiff submits the enclosed Proposed Stipulation and Order to extend the stay until at least August 27, 2022 with a further status report due on August 27, 2022. The parties are unable to submit a fully executed Proposed Stipulation and Order today and unable to provide a proposed schedule for further proceedings, as counsel for the City of New York is on family medical leave. The parties will supplement this status report with the fully executed Proposed Stipulation and Order as soon as possible.
We thank the Court for its consideration of this matter.
Respectfully submitted,
Jonathan C. Moore
STIPULATION AND ORDER
WHEREAS, THE PARTIES have conferred and determined that a continued stay of this matter is appropriate until at least August 27, 2022, in light of ongoing investigations by governmental authorities into the subject-matter of this lawsuit; and
WHEREAS, the Court previously further ordered, on consent, that this matter should be stayed until July 28, 2022;
IT IS HEREBY STIPULATED AND AGREED as follows:
1. All proceedings and deadlines in this matter should be stayed until at least August 27, 2022;
2. The parties shall submit a status report to the Court on August 27, 2022, proposing a schedule for further proceedings or stating if there is a disagreement regarding how to proceed;
3. The time for defendants to answer or otherwise respond to the complaint shall be adjourned until further order of the Court, to be determined at some time after August 27, 2022;
4. This stipulation is without prejudice to further requests for a stay or opposition to such a further request by any party.
SO ORDERED: