Case: Henrietta D. v. Giuliani

U.S. Court of Appeals for the Second Circuit

Henrietta D. v. Bloomberg

U.S. Court of Appeals for the Second Circuit

CLASS ACTION COMPLAINT filed and summons(es) issued for Rudolph Giuliani, Marva Hammons and Mary E. Glass. FILING FEE $ 120.00; RECEIPT # 169894. (Vaughn, Terry) (Entered: 02/24/1995)

MOTION by pltfs. Henrietta D., Nidia S., Simone A., Ezzard S., John R. and Pedro R. for preliminary injunction . Motion hearing set for 9:30 3/1/95 [2-1] motion . (Vaughn, Terry) (Entered: 02/24/1995)

MEMORANDUM by pltfs. Henrietta D., Nidia S., Simone A., Ezzard S., John R. and Pedro R. in support of [2-1] motion for preliminary injunction and class certification. (Vaughn, Terry) (Entered: 02/24/1995)

AFFIDAVIT by Lauren Shapiro, counsel to Brooklyn Legal Services Corp. B., on behalf of pltfs. Henrietta D., Nidia S., Simone A., Ezzard S., John R. and Pedro R. in support of [2-1] motion for preliminary injunction and class certification. (Vaughn, Terry) (Entered: 02/24/1995)

MEMORANDUM by pltfs. Henrietta D., Nidia S., Simone A., Ezzard S., John R. and Pedro R. in support of Ex Parte order permitting pltfs. to proceed anonymously. (Vaughn, Terry) (Entered: 02/24/1995)

AFFIDAVIT by Susan Kohlmann counsel for pltfs. Henrietta D., Nidia S., Simone A., Ezzard S., John R. and Pedro R. in [5-1] support of pltfs.' application to proceed anonymously. (Vaughn, Terry) (Entered: 02/24/1995)

RETURN OF SERVICE executed as to Rudolph Giuliani, Marva Hammons, and Mary E. Glass on 2/15/95. Answer due on 3/7/95 for Mary E. Glass, for Marva Hammons, and for Rudolph Giuliani. (Conte, Daniela) (Entered: 02/24/1995)

Calendar entry: before Judge Sifton on 2/21/95 at 4:30. Counsel for all parties present. Defendants are to serve and file a letter stating their position with respect to whether this case is related to CV-94-2842, by 2/22/95 at 5PM. The plaintiffs' motion for a preliminary injunction will be heard on 3/8/95 at 2PM. Defendants' papers in response are to be served and filed by 3/1/95. Any replies are to be served and filed by 3/7/95. (Conte, Daniela) (Entered: 02/24/1995)

CASE reassigned to Judge Sterling Johnson Jr. from Judge Sifton by random selection. (Guzzi, Roseann)

ORDER, dated 2/27/95, signed by Judge Charles P. Sifton. The action is to be reassigned by random selection. c/m (Conte, Daniela) (Entered: 03/01/1995)

LETTER dated 2/21/95 from Susan Kohlmann to Judge Sifton, Re: in support of plaintiff's claim that this action is related to CV-92-2842. (Conte, Daniela) (Entered: 03/02/1995)

LETTER dated 2/22/95 from Georgia Pestana to Judge Sifton, RE: in opposition to plaintiff's contention that this action is related to 94-CV-2842. (Conte, Daniela) (Entered: 03/02/1995)

LETTER dated 2/23/95 from Lauren Shapiro to Judge Sifton, RE: in support of relating this case to 94-CV-2842. (Conte, Daniela) (Entered: 03/02/1995)

AMENDED CLASS ACTION COMPLAINT by Henrietta D., Nidia S., Simone A., Ezzard S., and John R., Pedro R. (Answer due 3/16/95 ). Amending [1-1] complaint. (Yuen, Sui May) (Entered: 03/07/1995)

ORDER TO SHOW CAUSE: signed by Judge Charles P. Sifton, dated 2/24/95. Defendants are to show cause at 2/21/95 at 4:30 why an order should not be entered to hear plaintiff's preliminary injunction motion on an expedited basis; and plaintiff is to show cause why this action should be designated as a related case. (Conte, Daniela) (Entered: 03/08/1995)

EX PARTE ORDER signed by Judge Charles P. Sifton, dated 2/14/95, Re: permitting plaintiffs to proceed anonymously. (Conte, Daniela) (Entered: 03/08/1995)

CROSS MOTION by Douglas Israel, counsel for Rudolph Giuliani, Marva Hammons, Mary E. Glass to dismiss the complaint. Motion hearing set for 4/3/95. (Yuen, Sui May) (Entered: 04/04/1995)

MEMORANDUM by Douglas Israel, counsel for Rudolph Giuliani, Marva Hammons, Mary E. Glass in support of [24-1] cross motion to dismiss the complaint,and in OPPOSITION to plaintiffs' [2-1] motion for preliminary injunction and for class certification. (Yuen, Sui May) (Entered: 04/04/1995)

Calendar entry: before Mag. Caden on 3/22/95. Telephone conference was held. Mag. Caden acknowledged receipt of plaintiff's letter dtd 3/17/95 and dfts' response dtd 3/20/95. Three issues were raised : (1) plaintiff's request for a TRO enjoining acceptance of severance packages of certain city employees (DAS employees, Income Support/Aids of HRA). (2) plaintiffs' motion to amend the complaint (2nd). (3) plaintiff's request for expedited discovery on the preliminary injunction motion. As to the first issue (the TRO) the magistrate has no authority to hear argument or consider the request. No referral of the application has been made by Judge Johnson : parties were told to contact Judge Johnson's chambers on the same. As to the other issues (amending the complaint and expedited discovery) oral argument shall be heard on 3/23/95 at 3:30 - a court reporter shall be present. (Yuen, Sui May) (Entered: 03/24/1995)

Calendar entry: before Mag. Caden on 3/23/95. Adjourned to 5/28/95 at 5:00. (Yuen, Sui May) (Entered: 03/24/1995)

LETTER dated 3/7/95 from Georgia Pestana to Judge Johnson requesting that City Dfts be permitted to file a memorandum of law in excess of 30 pages. (Yuen, Sui May) (Entered: 03/24/1995)

LETTER dated 3/20/95 from Georgia Pestana to Mag. Caden in response to plaintiffs' counsels' 3/17/95 letter. (Yuen, Sui May) (Entered: 03/24/1995)

SECOND AMENDED CLASS ACTION COMPLAINT. (Answer due 4/10/95 for Mary E. Glass, for Marva Hammons, for Rudolph Giuliani ). (Yuen, Sui May) (Entered: 03/31/1995)

REPLY MEMORANDUM OF LAW by Henrietta D., Nidia S., Simone A., Ezzard S., John R., Pedro R. in further support of their [2-1] motion for preliminary injunction. (Yuen, Sui May) (Entered: 03/31/1995)

Nidia S's REPLY AFFIDAVIT in support of plaintiff's [2-1] motion for preliminary injunction. (Exhibits annexed). (Yuen, Sui May) (Entered: 03/31/1995)

Calendar entry: before Mag. Caden on 3/31/95. The magistrate judge directed the parties to proceed with expedited discovery on the issue of "irreperable harm." If the parties are not able to agree, among themselves, as to a schedule and as to the parametics of "irreparable harm" discovery, same will be discussed on 4/6/95 at 4:30. Parties can submit a schedule for the magistrate judge to "so ordered." (Yuen, Sui May) (Entered: 04/04/1995)

Calendar entry: before Judge Johnson on 3/31/95. Case called. All counsel present. Conference held. Plaintiff's application for TRO is denied. (Yuen, Sui May) (Entered: 04/04/1995)

LETTER dated 3/27/95 from Susan Kohlmann to Georgia Pestana and Ronald Youkins confirming that plaintiffs' brief will be served on 3/30; dfts' brief, 4/20; and plaintiff's reply, 4/27/95. (Yuen, Sui May) (Entered: 04/04/1995)

CROSS MOTION by Mary E. Glass to dismiss the second amended complaint. Motion hearing set for 9:00 5/8/95 [28-1] cross motion . (Yuen, Sui May) (Entered: 05/02/1995)

MEMORANDUM by Mary E. Glass in support of [28-1] cross motion to dismiss the second amended complaint. (Yuen, Sui May) (Entered: 05/02/1995)

MOTION by Rudolph Giuliani, and Marva Hammons to dismiss the complaint for failure to state a claim. Motion hearing set for 4/3/95 at 9:30. (Yuen, Sui May) (Entered: 05/16/1995)

MEMORANDUM by Rudolph Giuliani, Marva Hammons in support of their [30-1] motion to dismiss the complaint for failure to state a claim, and in OPPOSITION to plaintiffs' motion for a preliminary injunction. (Yuen, Sui May) (Entered: 05/16/1995)

Ronald Cavalier's DECLARATION in support of Rudolph Giuliani, and Marva Hammons's [30-1] motion to dismiss the complaint for failure to state a claim. (Exhibits annexed). (Yuen, Sui May) (Entered: 05/16/1995)

REPLY MEMORANDUM OF LAW by Henrietta D., Nidia S., Simone A., Ezzard S., John R., Pedro R. in further support of their [2-1] motion for preliminary injunction, and in OPPOSITION to dfts' motions to dismiss the second amended complaint. (Yuen, Sui May) (Entered: 05/16/1995)

MOTION by Rudolph Giuliani, Marva Hammons to dismiss for lack of jurisdiction. Motion hearing set for 5/8/95 at 9:30. (Yuen, Sui May) (Entered: 05/16/1995)

MEMORANDUM by Rudolph Giuliani, Marva Hammons in support of their [34-1] motion to dismiss for lack of jurisdiction, and in opposition to plaintiffs' motion for a preliminary injunction and class certification. (Yuen, Sui May) (Entered: 05/16/1995)

Calendar entry: before Mag. Caden on 6/15/95. Magistrate judge has entered certain orders which will be reduced to a writing regarding the obligation of dfts to produce certain documents. (Yuen, Sui May) (Entered: 06/20/1995)

First ORDER dtd 7/10/95 requiring production of documents. ( signed by Magistrate John L. Caden ). (Yuen, Sui May) (Entered: 07/14/1995)

CASE REFERRED to Magistrate-Judge Cheryl Pollak (Yuen, Sui May)

ORDER that parties are directed, within thirty days of receipt of this order, to file with the Clerk of the Court a written report on the status of the above-captioned case. the letter responding to this order, which should be no longer than two pages long, should be clearly marked as a Status Report.( signed by Magistrate-Judge Cheryl Pollak on 11.13.95 ) (Greene, Donna) (Entered: 11/21/1995)

STATUS REPORT (Greene, Donna) (Entered: 12/20/1995)

TRANSCRIPT filed for dates of 3.31.95 before Hn. Judge Johnson. Karen B. Dine, Esq. Armen H. Merjian, Esq. Virginia Shubert, Esq. Michael Kink, Esq., Theresa M. Mc Govern, Esq., Richardo Castro, Esq. for pltf. Douglas Espel, for deft. Mary E. Glass. Georgia Pestana for deft Giuliani and Hammons. (Greene, Donna) (Entered: 12/21/1995)

LETTER dated 2.9.96 from Susan J. Kohlmann to Mag. Judge Pollak, writing to confirm her conversation with Ms. Roberson that Your Honor has scheduled a status conference in the above-referenced matter on March 14 at 2:30 p.m. (Greene, Donna) (Entered: 02/13/1996)

Calendar entry: Before Mag. Judge Pollak on 3/14/96 at 2:30 p.m. Case called. Pltf.'s are to proceed with depositions of Mr. Dwarken and Ms. Calogne. If they determine that the information obtained is not sufficient for a TRO, they should contact the Court by phone to discuss deposition of sit supervisor. Court will consider motion before Judge Caden (previously briefed) but parties are ordered to provided the Court with a list of papers previously submitted so the Court can be sure all submissions are in the file. Court will review document production request. Next status conference for 11:30 4/17/96 before Magistrate-Judge Cheryl Pollak . (Greene, Donna) (Entered: 03/26/1996)

Calendar entry before Mag. Pollak dated March 27, 1996. Pltffs request for deposition of Brooklyn site director granted but limited to 3 hours so as to avoid undue disruption of site transfers and closings. (Joseph, Derek) (Entered: 04/23/1996)

LETTER dated 7/17/95 from Georgia Pestana to Mag. Caden, with respect to plaintiffs' first order requiring production of documents. (Dobkin, David) (Entered: 03/29/1996)

LETTER dated 7/5/95 from Susan Kohlmann to Mag. Caden, re: copies of the propsed orders requiring production of documents. w/o enclosures. (Dobkin, David) (Entered: 03/29/1996)

LETTER dated 3/20/95 from Georgia Pestana to Mag. Caden pltff's should not be granted the opportunity to engage in discovery until they have demonstrated they have a colorable claim (Jackson, Ramona) (Entered: 04/01/1996)

LETTER dated 6/9/95 from Ricardo Castro to Mag. Caden confirm conf. for June 15,1995 @ 10:00 (Jackson, Ramona) (Entered: 04/01/1996)

LETTER dated 7/6/95 from Georgia Pestana to Mag. Caden deft's request the court not to sign the order requiring production of documents (Jackson, Ramona) (Entered: 04/01/1996)

LETTER dated 7/7/96 from R Castro to Mag Caden response to letter dtd. 7/6/95 requiring proposed orders submitted in 7/5/95 (Jackson, Ramona) (Entered: 04/01/1996)

Calendar entry: Before Mag. Judge Pollak on 4/17/96 at 11:30 a.m. Deft.'s are to provide documents requested by pltf.'s at depositions within 2 weeks. Documents objected to on privilege grounds to be submitted to the Court for in camera inspection by Friday April 19. Pltf.'s to notify court and deft.'s by May 17 whether intend to seek a TRO or Preliminary Injunction at this time. (Greene, Donna) (Entered: 04/23/1996)

LETTER dated 4/9/96 from Lauren Shapiro to Mag. Judge Pollak, advising that there office is no longer representing the pltf. class in the above referenced action. (Greene, Donna) (Entered: 04/18/1996)

LETTER dated 4/5/96 from Georgia Pestana to Mag. Judge Pollak, In re: as pltf.'s counsel's cover letter did not itemize the documents enclosed as a complete set of papers submitted on the issue of deliberative process, the following is a list of the documents relating to the issue. ( See letter for List). (Greene, Donna) (Entered: 04/22/1996)

LETTER dated 4/22/96 from Georgia Pestana to Magistrate Pollak, Re: Enclosing two draft reports prepared by Allen Kraus, to study the Division of Aids Services and to recommend changes to improve the efficiency and effectiveness of the program. (Piper, Francine) (Entered: 04/30/1996)

LETTER dated 5/20/96 from Susan J. Kohlmann to Mag. Judge Pollak, advising the Court that plaintiffs do not intend to move to restrain implementation of the City's current plan for restructuring the Division of AIDS Services. (DiTomasso, Mike) (Entered: 05/28/1996)

ORDER that defendants are to produce the non-redacted factual portions of the documents as described on this order on page 7 to plaintiffs on or before 8/23/96. ** refer to this document for details ** (signed by Magistrate Cheryl L. Pollak, dated 8/9/96) (Asreen, Wendy) (Entered: 08/15/1996)

SEALED DOCUMENT containing "Division of Aids Services : Management Review". placed in vault. (Yuen, Sui May) (Entered: 09/06/1996)

ORDER dated 9/6/96; support motion papers are due by 9/30/96 set status conference for 9:30 9/30/96 before Judge Sterling Johnson Jr. ( signed by Judge Sterling Johnson Jr. ) (Dobkin, David) (Entered: 09/11/1996)

Plaintiffs' Report of Developments in the Case. (Greene, Donna) (Entered: 09/23/1996)

Declaration by Georgia Pestana in support of dft.'s motion to dismiss and in opposition to pltf.'s motion for a p reliminary injunction. (Greene, Donna) (Entered: 10/07/1996)

Calendar entry: Before Hon. Judge Johnson on 9/30/96 at 9:30 a.m. Case called; further status conference for 9:30 10/29/96 before Judge Sterling Johnson Jr. . Motion for preliminary Injunction. (Greene, Donna) (Entered: 10/08/1996)

LETTER dated 9/30/96 from Asst. Corp. Counsel, Georgia Pestana, to Judge Johnson, submitting materials which are used by HRA's Division of AIDS Services and Income Support to monitor clients' access to benefits and services. (Asreen, Wendy) (Entered: 10/22/1996)

LETTER dated 10/4/96 from Susan Kohlmann, Esq., to Judge Johnson in opposition and in response to Georgia Pestana's letter with atachments dated 9/30/96. (Asreen, Wendy) (Entered: 10/22/1996)

Calendar entry: Pretrial conference held with Judge Johnson on 10/29/96. Court reporter: Anthony Mancuso. All discovery issues referred to Magistrate Pollak. Set jury trial for 9:30 on 2/10/97 before Judge Sterling Johnson Jr. . (Asreen, Wendy) (Entered: 10/30/1996)

MEMORANDUM AND ORDER for the reasons stated herein, pltf.'s motion for preliminary injunction and deft.'s motion to dismiss are DENIED. Pltf.'s motion for class certification is GRANTED. (signed by Judge Sterling Johnson Jr. on 10/25/96). (Greene, Donna) (Entered: 11/04/1996)

ANSWER by Rudolph Giuliani, Marva Hammons to second amended complaint. (Greene, Donna) (Entered: 11/13/1996)

ANSWER by Mary E. Glass to second amended complaint. (Greene, Donna) (Entered: 11/20/1996)

COPY OF LETTER dated 12/20/96 from Georgia Pestana to Susan J. Kohlmann, stating that Dan McCarthy's deposition is still set for 1/8/97, but will not produce witnesses and discovery when pltfs. are uncooperative. (Greene, Donna) (Entered: 01/07/1997)

TRANSCRIPT filed for conference [63-1] held on 10/29/96 before Judge Sterling Johnson Jr.. Court reporter: Anthony Mancuso. (Asreen, Wendy) Modified on 01/13/1997 (Entered: 01/13/1997)

Calendar entry: Status conference before Mag. Judge Pollak on 1/10/97. Defendant to provide plaintiffs with sample documents underlying computer runs; to identify the individual (or individuals) in the computer systems area familiar with the programs and data and to produce them for deposition before 1/17/97. parties to contact Court after deposition for status . (DiTomasso, Mike) (Entered: 01/16/1997)

Calendar entry: Before Mag. Pollak on 1/17/97 at 10:00. Case called. Next conference scheduled for 4:00 on 2/24/97 before Magistrate-Judge Cheryl L. Pollak . Discovery schedule set. Parties are to confer regarding outstanding document production and documents are to be produced by Jan. 31. Depositions are to be completed by Feb. 17. Conference set for Feb. 24 at 4:00 to set expert discovery. (Greene, Donna) (Entered: 01/29/1997)

Calendar entry: Before Mag. Pollak on 2/11/97. Case called. City to provide copy of preliminary report and questionaire for in camera inspection. (Greene, Donna) (Entered: 02/19/1997)

LETTER dated 2/13/97 from Susan J. Kohlmann to Mag. Pollak, writing in reply to the City defts. letter to Your Honor dated 2/12/97 in connection with their continued refusal to produce any part of the preliminary report or the raw data in connection with a study of the client base of the Division of AIDS Services and Income Support (DASIS). (Greene, Donna) (Entered: 02/20/1997)

ORDER dated 2/14/97, this Court orders defts. to produce the Memorandum dated 1/21/97 to pltfs. on or before 2/19/97. ( signed by Magistrate-Judge Cheryl L. Pollak on 2/14/97). (Greene, Donna) (Entered: 02/24/1997)

Calendar entry: Telephone status conference held with Magistrate Pollak on 2/24/97. Plaintiffs' request for underlying data to preliminary report is denied subject to reconsideration following completion of report within the next two weeks. Set next status conference for 11:00 on 3/17/97 before Magistrate-Judge Cheryl L. Pollak . (Asreen, Wendy) (Entered: 03/03/1997)

Calendar entry: Before Mag. Pollak on 3/17/97 at 11:00. Case called. Defts. inform Court that report not completed as promised; that preliminary report on pre-restructuring phase expected in two weeks, remaining portions of report expected in June. Court orders production of underlying raw data, redacted as to survey respondents personal identifying information to be produced to pltfs. by March 31. Next conference set for 2:30 on 4/3/97 before Magistrate-Judge Cheryl L. Pollak . (Greene, Donna) (Entered: 03/19/1997)

Calendar entry: Before Mag. Pollak on 3/31/97. Case called. Next conference scheduled for 4:30 on 4/10/07 before Magistrate-Judge Cheryl L. Pollak . Defts. given one additinal week to provide copies of survey responses- April 4. Conference adjourned to April 10 at 4:30 by phone. (Greene, Donna) (Entered: 04/07/1997)

Calendar entry: Before Mag. Pollak on 4/10/97 at 4:30. Case called. Next conference scheduled for 9:30 on 7/3/97 by phone before Magistrate-Judge Cheryl L. Pollak . Parties are directed to conduct depositions. (Greene, Donna) (Entered: 04/18/1997)

Calendar entry: Before Mag. Pollak on 7/3/97 at 9:30. Case called. Next conference schedule for 5:00 on 9/11/97 before Magistrate-Judge Cheryl L. Pollak . Defendants to object or produce documents requested at the Caldwell deposition by 7/11. The depositions of Caldwell, Fetchy and Ramime are to be completed by 8/29. Curtahy's depositon to be completed by 7/31. Conference Sept. 11 at 5:00 to schedule expert discovery. (Greene, Donna) (Entered: 08/04/1997)

COPY OF LETTER dated 9/5/97 from Susan J. Kohlmann to Mag. Pollak, requesting postponement of the discovery confernce currently scheduled for 9/11/97 at 5:00 for three or four weeks. (Greene, Donna) (Entered: 09/30/1997)

Endorsed order on doc. #79. Application granted. Discovery adjourned to 11:30 on 10/3/97 ( Signed by Magistrate-Judge Cheryl L. Pollak on ). (Greene, Donna)

Calendar entry: Before Mag. Pollak on 10/3/97 at 11:30. Case called. Next conference for 9:00 12/8/97 before Magistrate Cheryl L. Pollak . Deft. to produce documents for in camera inspection by 10/10. Discovery order entered. (Greene, Donna) (Entered: 10/16/1997)

LETTER dated 10/6/97 from Kathleen P. Murray to Mag. Pollak, writing the court to apologize for her oversight, and not appearing at the 10/3/97 conference. (Greene, Donna) (Entered: 10/16/1997)

ORDER that on or before 10/24/97, defts. will file with this Court a representation that City defts. counsel have reviewed pltfs. prior discovery requests and that all responsive documents have been produced or identified and made available for review by pltfs. Ordered that on or before 10/17/97, City defts. will identify individuals with knowledge of the WMS System and the actual and potential ability of that system to be used for monitoring the performance of DAS. Ordered that on or before 11/21/97 the parties will have compled the depositions of Mr. Remine, Mr. Caminiti, Mr. Caldwell and any individuals identified pursuant to this order. ( signed by Magistrate Cheryl L. Pollak on 10/3/97). (Greene, Donna) (Entered: 10/17/1997)

ORDER that this Court having conducted an in camera inspection to determine whether the disputed documents are in fact privileged, finds that a Memorandum, dated 7/7/97, from Mr. Remine to mr. Caldwell and other is predecisional and protected in its entirety from production. A second Memorandum, dated 3/3/97, from Mr. Remine to Mr. Caldwell and others consists of two preliminary pages regarding future projections of staff which are pre-decisional and protected from production, as well as several pages containing charts, comparing 1997 real and planned program staffing for various locations. To the extent that these documents contain existing staffing figures they should be produced, with the columns labeled "Planned Staff" or "N" (needs) redacted. Finally, with respect to the remaining two documents, portions of which defts. have proposed redactions, this Court has reviewed the proposed redactions and agrees that these portions of the documents should be subject to protection. Accourdingly, this Court orders that those documents be produced as redacted. ( signed by Magistrate Cheryl L. Pollak on 10/21/97). (Greene, Donna) (Entered: 11/04/1997)

LETTER dated 10/10/97 from Musako C. Shiono to Mag. Pollak, enclosing the Declaration of Gregory Mark Caldwell, along with four documents for which defts. assert the pre-decisional or deliberative process privilege in whole or in part. He has indicated on the two partially withheld documents the portion of the document for which the privilege has been asserted. (NO ENCLOSURE). (Greene, Donna) (Entered: 11/05/1997)

MAIL RETURNED. Order dated 10/21/97 mailed to Clinton F. Eubanks returned on 11/12/97. "Return to Sender - Attempted Unknown". (Greene, Donna) (Entered: 11/12/1997)

LETTER dated 11/12/97 from Masako C. Shiono to Magistrate Pollak requesting that the defendants time to complete the depositions be extended to 12/12/97. (Guzzi, Roseann) (Entered: 12/15/1997)

Endorsed order dated 11/12/97 granting defendants request to extend time to complete depositions. C/M ( Signed by Magistrate Cheryl L. Pollak ) (Guzzi, Roseann)

ORDER adjourning the 12.8.97 telephone conference until 12:00 on 1/6/98 before Magistrate Cheryl L. Pollak . (signed by Magistrate Cheryl L. Pollak, undated) See letter dated 12.5.97 from Armen H. Merjian to Magistrate Pollak. Galeano, Sonia (Entered: 12/17/1997)

Calendar entry:, Before Mag. Pollak on 1/6/98 for a Telephone Conference. Pltffs expert reports due 2/9. Defendant's experts (if any) reports due 3/13. Depositions of all experts to be completed by 4/10. Set Telephone Conference for 4:00 4/21/98 before Magistrate Cheryl L. Pollak . (Piper, Francine) (Entered: 01/07/1998)

ORDER dtd. 2/6/98 Request GRANTED On ltr. dtd. 2/4/98 from Susan J.Kohlmann Pltff's expert reports 2/23/98; Deft's expert reports 3/27/98. Close of discovery to 4/24/98 ( signed by Magistrate Cheryl L. Pollak ) Copies mailed (Jackson, Ramona) (Entered: 02/09/1998)

LETTER dated 2/23/98 from Susan J. Kohlmann to Mag. Pollak, requesting a second and final two-week extension of the current expert discovery schedule. Accordingly, their requesting that pltfs. expert report be due 3/9/98, defts. 4/10/98, and the close of expert discovery be extended to 5/8/98. (Greene, Donna) (Entered: 03/02/1998)

Endorsed order on doc. #90. Request granted, expert discovery for pltf. due 3/9/98, defts. report due 4/10/98, and the close of discovery extended to 5/8/98. ( Signed by Magistrate Cheryl L. Pollak on 2/25/98). c/m (Greene, Donna)

LETTER dated 3/9/98 from Susan J. Kohlmann to Mag. Pollak, enclosing courtesy copies of the expert report of Dr. Ernest Drucker, and Dr. Tanya Zangaglia. (Greene, Donna) (Entered: 03/17/1998)

ORDER, granting defendants' requests to adjourn expert reports to 5/22/98 and to extend time to complete expert depositions to 6/22/98 . Telephone conference adjourned to 9:30 on 6/30/98 . (Signed by Magistrate Cheryl L. Pollak, dated 4/15/98). C/M by Chambers. See letter dated 4/13/98 from Deborah Lee Stachel to Magistrate Judge Pollak. (Reddy, Lisa) (Entered: 04/16/1998)

ORDER, granting defendants request to extend time . Defendants' expert reports due 6/19/98; parties to take depositions within 30 days thereafter, or until 7/20/98. Conference rescheduled for 11:30 on 8/13/98 . (Signed by Magistrate Cheryl L. Pollak, dated 6/11/98). C/M by Chambers. See letter dated 6/10/98 from Masako C. Shiono to Magistrate Judge Pollak. (Reddy, Lisa) (Entered: 06/17/1998)

LETTER dated 7/16/98 from Masako C. Shiono to Mag. Pollak, advising that the parties respectfully request additional time within which to schedule the expert depositions. In addition, municipal defts respectfully request that the time of the conference on 8/13 be changed. (Greene, Donna) (Entered: 07/28/1998)

Endorsed order on doc. #94. Application granted. Conference adjourned to 8/14/98 at 10:30. ( Signed by Magistrate Cheryl L. Pollak). (Greene, Donna)