Judge Alvin K. Hellerstein — United States District Court, Southern District of New York

Civil Case Management Plan

UNITED STATES DISTRICT COURT (Effective 2/28/2025) SOUTHERN DISTRICT OF NEW YORK ---------------------------------------------------------------x : _____ Civ. __________ (AKH) : : Plaintiff(s), : : CIVIL CASE MANAGEMENT PLAN -against- : : :
: : : Defendant(s). : : ---------------------------------------------------------------x After consultation with counsel for the parties, the following Case Management Plan is adopted. This plan is also a scheduling order pursuant to Rules 16 and 26(f) of the Federal Rules of Civil Procedure. A. The case (is) (is not) to be tried to a jury. [Circle as appropriate]. B. Non-Expert Discovery: 1. The parties are to conduct discovery in accordance with the Federal Rules of Civil Procedure and the Local Rules of the Southern District of New York. All non-expert discovery is to be completed by _______________, which date shall not be adjourned except upon a showing of good cause and further order of the Court. Interim deadlines for specific discovery activities may be extended by the parties on consent without application to the Court, provided the parties are certain that they can still meet the discovery completion date ordered by the Court. a. The parties shall list the contemplated discovery activities and anticipated completion dates in Attachment A, annexed hereto. 2. Joinder of additional parties must be accomplished by _______________. 3. Amended pleadings may be filed without leave of the Court until ____________________. C. For all causes of action seeking monetary damages, each party shall identify and Page 1 of 5

quantify in Attachment B, annexed hereto, each component of damages alleged; or, if not known, specify and indicate by what date Attachment B shall be filed providing such information. D. Motions, Settlement, Second Pre-Trial Conference, and Expert Discovery: 1. Upon the conclusion of non-expert discovery, counsel for the parties shall meet for at least two hours at the office of plaintiff’s counsel, to discuss settlement. The date for the meeting is _______________, at _________.m. (Counsel shall insert a date but, at the option of either, the date may be canceled upon the service or filing of a dispositive motion and notice to the court.) a. There shall be no cross-motions. 2. Approximately one week thereafter, the parties shall meet with the Court for a Second Case Management Conference to discuss the status of the case, the prospects of settlement, whether alternative disputes-resolution procedures should be utilized, the need for and a schedule regulating experts and expert-discovery, appropriate motions and schedules therefor, and any other issue counsel or the Court wish to discuss. The Case Management Conference will be held on Friday, _________________, at 10:00 a.m. 3. As to motions, there shall be no more than three rounds of serving and filing papers: supporting affidavits and briefs, opposing affidavits and briefs, and reply affidavits and briefs. Page 2 of 5 Any request for relief from any date provided in this Case Management Plan shall conform to the Court’s Individual Rules, and include an order, showing consents and disagreements of all counsel, setting out all dates that are likely to be affected by the granting of the relief requested, and proposed modified dates. Unless and until the Court approves the proposed order, the dates provided in this Plan shall be binding. E.

DATED:
F. A final pre-trial conference will be held on a date to be set, as close as possible to the date that trial is expected to begin. The parties, three days before said meeting, shall submit their pre-trial order, conforming to the Court’s Individual Rules and, at the conference, deliver their exhibit books containing all exhibits the parties actually intend to offer at the trial. G. Pre-Trial Motions: Applications for adjournments and for discovery or procedural rulings will reflect or contain the positions of all parties, and otherwise conform to my Individual Rules 1(D) and 2(E). SO ORDERED. New York, New York ____________________, 20

ALVIN K. HELLERSTEIN United States District Judge Page 3 of 5

ATTACHMENT A
The Parties are to list the discovery activities (i.e., production of documents, number of depositions, requests to admit, interrogatories) and anticipated completion dates:
DISCOVERY ACTIVITIES COMPLETION DATE 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. Page 4 of 5

ATTACHMENT B For all causes of action seeking monetary damages, each party shall identify and quantify each component of damages alleged:
1. PLAINTIFF’S CLAIMS: 2. COUNTERCLAIMS AND CROSS-CLAIMS: 3. THIRD-PARTY CLAIMS: Page 5 of 5

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------------------X [JANE DOE], Individually and on

        : 

Behalf of All Other Persons Similarly Situated, : FORM NOTICE TEMPLATE :
[14 Civ. 1234] (AKH) Plaintiffs, : : -against- :
:
[JOHN DOES],

: : Defendants. :
: --------------------------------------------------------------X NOTICE OF COLLECTIVE ACTION LAWSUIT TO: [DEFINE CLASS] DATE: RE: Fair Labor Standards Act Lawsuit filed against [DEFENDANTS] I. WHAT THE LAWSUIT IS ABOUT [SUMMARIZE COMPLAINT] II. COMPOSITION OF THE COLLECTIVE ACTION The named Plaintiff seeks to sue on behalf of herself, and on behalf of other employees who may wish to join her lawsuit and who are similarly situated.
III. NO OPINION EXPRESSED AS TO THE MERITS OF THE CASE Although the Court has authorized the Plaintiff to send this Notice, the Court expresses no opinion regarding the merits of the claims. This Notice should not be taken as an indication that you should or should not join this lawsuit.

IV. YOUR OPTIONS REGARDING THE LAWSUIT You may elect to join this lawsuit, bring your own separate lawsuit, or not do anything. If you intend to join the lawsuit, you must complete the enclosed consent to become a plaintiff form by [insert 45 days from the date of notice] ______ __, and send it to the following address: [PLAINTIFF ATTORNEY NAME] [STREET ADDRESS] [TELEPHONE & FAX] [EMAIL] You may elect to participate in the lawsuit using [PLAINTIFF’S ATTORNEY NAME] as your counsel, or you may join using your own counsel. [PLAINTIFF’S ATTORNEY NAME] will promptly file the elections to join that he receives. V. EFFECT OF JOINING THIS ACTION If you choose to join this lawsuit, you will be bound by any outcome, whether favorable or unfavorable. If the Plaintiff and anyone else who joins this lawsuit prevail at trial, or a settlement is reached, you may be entitled to share in any money recovered, less your share of expenses, including the fees and expenses of plaintiffs’ lawyers as may be allowed by the court. On the other hand, if the [DEFENDANTS] prevail, you may not recover any money. If you choose to join the lawsuit, and while the suit is proceeding, you may be required to answer written questions, provide information and documents (including electronic records), appear for a deposition to give testimony under oath, and testify in court. You can also join this lawsuit by counsel of your own choosing. If you do so, your attorney must file an “opt-in” consent form by ___________________ [insert date that is 45 days from date of notice mailing].
VI. EFFECTS OF NOT JOINING THIS LAWSUIT If you choose not to join this lawsuit, you do not need to do anything. If you do not join this lawsuit, you will not be a part of the case in any way, and will not be bound by any resolution, whether favorable or unfavorable. You should be aware that a claim under the FLSA must be brought within two (2) years of the date the claim accrues, unless you can prove that your employer’s violation was “willful,” in which case the claim must be brought within three (3) years.

VII. NO RETALIATION PERMITTED Federal and state law prohibits an employer from discriminating or retaliating against you for choosing to join this lawsuit or otherwise exercising your existing rights under the FLSA. VIII. LEGAL REPRESENTATION FOR THE DEFENDANTS The [DEFENDANTS] are represented by [DEFENDANTS’ ATTORNEY NAME, FIRM NAME, AND CITY WHERE FIRM IS LOCATED]. CONSENT TO JOIN

1. [STATE YOUR NAME, ADDRESS, AND PHONE NUMBER]
2. [STATE OF YOUR WISH TO BE REPRESENTED BY YOUR OWN ATTORNEY, STATE YOUR ATTORNEY’S NAME, ADDRESS, AND PHONE NUMBER. IN ORDER TO REPRESENT YOU THAT ATTORNEY MUST FILE A NOTICE OF APPEARANCE WITH THE CLERK OF THE COURT.]
3. [STATE THE RELEVANT FACTS, CIRCUMSTANCES, AND DATES AS TO WHICH YOU BELIEVE YOU ARE SIMILARLY SITUATED WITH PLAINTIFF AS TO THE SAME EMPLOYER NAMED IN THE LAWSUIT.]
4. SIGN BEFORE A NOTARY PUBLIC.

Individual Rules

INDIVIDUAL RULES OF THE HONORABLE ALVIN K. HELLERSTEIN UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

Effective October 23, 2025

Chambers

Courtroom Room 1050

Room 14D United States Courthouse

United States Courthouse 500 Pearl Street

500 Pearl Street

New York, New York 10007

New York, New York 10007 Tel: (212) 805-0152

(212) 805-0152 Fax: (212) 805-7942

Unless otherwise ordered by Judge Hellerstein, matters before him shall be conducted in accordance with the following practices:

1. Communications with Chambers. In general, there should be no need to communicate with Chambers. All information related to a case can be obtained by visiting the Court’s Electronic Case Filing (“ECF”) system.

A. Letters. Parties shall send to Chambers a hard copy of all letters. Copies of letters to Chambers shall simultaneously be delivered to all counsel in no less speedy a manner than the method of delivery to the Court. Counsel shall not copy the Court on correspondence between and among them. Refer to Rule 2.E below for letters concerning disputes. Parties are not permitted to file letter motions and briefs in lieu of formal motions, unless special permission to do so is granted.

B. Method of Delivery. Copies of all documents shall either be mailed to Chambers or left with the Court Security Officer at the Worth Street entrance of the Courthouse. Papers shall not be delivered directly to Chambers unless special permission to do so is granted.

i. Faxes. Faxes may be sent only: for urgent matters requiring an immediate response from Chambers; to request an adjournment or extension of time as provided by Rule 1.D; or to make a technology request as provided by Rule 1.F. Faxes should be brief and may not exceed 5 pages without special permission from Chambers. Do not follow faxes with a hard copy.

ii. ECF. Letters filed on ECF must also be sent to Chambers, either by mail or, if five pages or under, by fax.

C. Telephone Calls. Phone calls are not permitted (i) to seek adjournments, (ii) for inquiries as to the status of a pending motion, (iii) for oral interpretation or clarification of written orders, or (iv) to seek guidance on procedures that are governed by these Individual Rules, the Local Rules of this Court, or the Federal Rules.

D. Requests for Adjournments or Extensions of Time. All requests for adjournments (including adjournments of court conferences) or extensions of time must be made in writing at least 48 hours before the scheduled deadline or date of appearance. All requests must state: (i) the original date; (ii) the number of previous requests for adjournment or extension; (iii) whether these previous requests were granted or denied; (iv) whether the adversary consents, and, if not, the reasons by the applicant, and by the adversary, for and against the relief requested; and (v) all other dates previously scheduled after the original date, including dates for conferences with the Court, and a suggested modified schedule, agreed to by all other counsel. Requests for adjournments should be faxed to (212- 805-7942).

i. DO NOT call Chambers or the Courtroom (i) to announce your intention to request an adjournment, (ii) to inquire about the status of your request, (iii) to confirm that your request has been received, unless more than 5 business days have lapsed since you sent your request, or (iv) to ask permission to fax a letter requesting an adjournment or extension. Requests for adjournments or extensions of time may be made by fax without advance permission.

ii. DO NOT file requests for adjournments or extensions of time on ECF without also sending a hard copy or fax of the request to Chambers. (See 1(B)(ii).)

E. ECF Cases. All civil and criminal cases (except pro se and special cases) filed on or after March 1, 2004 assigned to Judge Hellerstein are ECF cases. All counsel must register for ECF in each case pending before this Court. Counsel are responsible for checking their registered email and court docket sheet for memo- endorsements and orders. If counsel are not receiving such emails, please contact the ECF Help Desk at (212) 805-0800. All filings on ECF which can be made text-searchable shall be text-searchable.

F. Technology Requests. Under appropriate circumstances, counsel may bring laptops and other technology, such as projectors, into the courtroom. Counsel who wish to bring such technology into the courtroom must fill out the technology request form provided on the Court’s website (under Local Rules/Standing Orders – Electronic Device Order). Counsel shall submit a hard copy of the request, along with a letter explaining the need for the technology requested. The letter and technology form may be faxed to Chambers.

2. Conferences, Pleadings & Motions.

A. Conferences in Civil Cases. Remote conferences in all civil cases will generally be called after Answers are filed and on Fridays at 10:00 a.m. All conferences for that day will be called sequentially beginning at 10:00 a.m. Lawyers in charge of the case shall be present on the telephone call. They shall join the call starting at 9:50 a.m. No later than 48 hours prior to an initial conference, counsel shall file, via ECF, a proposed case management plan, using the template attached to these individual Rules. For all other conferences, counsel shall submit by email to Chambers a joint agenda, no later than 48 hours in advance of the conference.

B. Motions. Counsel shall not request a pre-motion or permission to file a motion.
Motions may be filed in the discretion of the attorneys, and shall conform to the Federal Rules of Civil Procedure. Letter motions or oppositions will not be accepted.

C. Filing of Motion Papers. Motion papers shall be filed promptly after service. All motions, and courtesy copies of all motions, shall include a table of contents listing all affidavits and exhibits. The Court does not impose a page limit for briefs.

i. Affidavit and Exhibit Requirements. All affidavits and exhibits shall conform to the following requirements.

I. Affidavits and exhibits shall be clearly identified by tabs on both original and courtesy copies.

II. All affidavits, exhibits, and motions shall be bound.

III. Exhibits shall be marked sequentially such that no exhibit number or letter repeats, regardless of the affidavit to which it is attached.
Exhibits for plaintiffs should be marked by numbers; exhibits for defendants should be marked by letters. Parties shall refer to exhibits already filed and not duplicate them.

D. Oral Argument on Motions. Motions shall be returnable on any day of the week.
Counsel shall not appear in Court on the return date. The Court will schedule the date and time for argument if it desires argument.

E. Disputes. Unless directed otherwise, counsel shall describe their disputes in a single letter, jointly composed. Separate and successive letters will be returned, unread. Strict adherence to the meet and confer rule is required and should be described in the joint submission as to time, place and duration, naming the counsel involved in the discussion. The Court will not resolve disputes not brought to its attention in conformity with this rule.

F.
Courtesy Copies. Parties shall send to Chambers one courtesy copy of all pleadings, motions, and supporting papers, except motions for admission pro hac vice. In the event of an especially voluminous submission, and only with written approval from Chambers, parties may submit their exhibits by CD. In any event, courtesy copies are to be submitted without plastic covers.

G.
Special Rules for Patent Cases. In a case of patent infringement, the first step after issue is drawn and prior to the Initial Case Management Conference provided by Fed. R. Civ. P. 26(f), will be a Markman hearing. Markman v. Westview Instruments, Inc., 517 U.S. 370 (1996). This shall be the procedure. i. Plaintiff shall convene a meeting with Defendant, as soon as practicable after issue is drawn, to review the patent claims and to identify which parts of the claim require judicial definition, as requested by either party. A four-column table shall be created, the first column of which shall identify, line by line, the portions of the claim requiring judicial interpretation.

ii. Within two weeks thereafter, Plaintiff shall populate the second column of the table with its proposed interpretations of all phrases set out in the first column, and produce the table to Defendants.

iii. Within two weeks thereafter, Defendant shall populate the third column of the table with its proposed interpretations, agreeing and disagreeing with Plaintiff’s proposed interpretations.

iv. Promptly thereafter, the parties shall meet to seek agreement as to their differing proposed interpretations, and revise columns two and three to reflect their agreements. The revised table shall be filed. The parties then shall call Chambers to schedule a Markman hearing.

v. At or following the hearing, the Court shall (i) populate the fourth column of the table with its rulings, and file same as its Order regulating all further proceedings, and (ii) set times for motions, Initial Disclosures, and the Initial Case Management Conference.

H.
Special Rules for Bankruptcy Appeals. In an appeal from an order of a bankruptcy court, the appellant shall file, promptly after respondent appears and after consultation with respondent, a proposed schedule for the filing of appellant’s

and respondent’s briefs, and appellant’s reply brief. The briefing period shall not extend beyond 90 days after respondent appears in the action.
I.
Default Judgments. Plaintiffs moving for a default judgment shall attach proofs of service and of either the agency relationship between the Defendant and the individual who received process, or a description of compliance with the rule or statute pursuant to which service was made. If a default judgment is sought against an entity, plaintiff shall include in their supporting papers a copy of the charter of said entity, along with a discussion of how service was made and what kind of legal entity the Defendant is, including any corporate designations.

3. Pretrial Procedures

A. Joint Pretrial Orders in Civil Cases. Following the close of discovery, unless otherwise ordered by the Court, a final pretrial conference will be scheduled as close as possible to the date that the trial is scheduled to begin. The parties shall submit, three days prior to that conference, for the Court’s approval, a joint pretrial order, which shall include the following:

i. The full caption of the action, omitting all dismissed parties.

ii. The names, addresses (including firm names), e-mail addresses, and telephone and fax numbers of trial counsel.

iii. A brief statement by plaintiff as to the basis of subject matter jurisdiction, and a brief statement by each other party as to the presence or absence of subject matter jurisdiction. Such statements shall include citations to all statutes and cases relied on and relevant facts as to citizenship and jurisdictional amount.

iv. A brief summary of the claims and defenses to be tried, without recital of evidentiary matter but including citations to all statutes and cases relied on.

v. A copy of the pleadings marked to show, for each claim and defense, in the margin next to each allegation thereof, the admissions and denials; and if any claims or defenses have been withdrawn or previously determined.

vi. A statement as to whether the case is to be tried with or without a jury, and the estimated number of trial days (including direct and cross-examination for all witnesses).

vii. A statement as to whether or not all parties have consented to trial of the case by a magistrate judge (without identifying which parties have or have not so consented).

viii. Any stipulations or agreed statements of fact or law.

ix. A list of each party’s witnesses actually intended to be called, and, if the witness cannot be present and will testify through deposition, the precise portions of deposition transcripts actually intended to be introduced together with any cross-designations and objections by any other party.

x. A list of exhibits actually intended to be offered at trial, indicating exhibits to which no party objects on grounds of authenticity and exhibits to which no party objects on any ground. Exhibits for plaintiffs should be marked by numbers; exhibits for defendants should be marked by letters; and plaintiffs and defendants shall bring to the conference loose-leaf exhibit binders of all exhibits they actually intend to offer at the trial. Defendants shall not duplicate exhibits identified by Plaintiffs.

B. Filings Prior to Trial in Civil Cases. On or before a date set by the Court, and no later than three days before the final pretrial conference, each party shall submit, in duplicate:

i. For jury and non-jury trials, a pretrial memorandum, describing the party’s position on the factual and legal issues to be tried.

ii. For jury trials, proposed requests to charge and proposed voir dire questions.

iii. For non-jury trials, proposed findings of fact and conclusions of law for each claim and defense.

iv. The submissions described in ii and iii above shall be in both hard copy and electronically in MS Word format (by email or CD-Rom).

v. Motions in limine will be heard at the final pre-trial conference. Counsel shall schedule the motions to suit their convenience, providing sufficient time for the court to understand, and rule on, the disputed issues.

C. Filings Prior to Trial in Criminal Cases. The procedures for trials in criminal cases shall be the same (to the extent practicable) as the procedures for trials in civil cases.

4. Confidentiality Provisions.

A. Protective Orders. Court records and docket sheets are to be accessible to the public, and enjoy a presumption of openness to public inspection. The presumption is rebuttable upon demonstration that “closure is essential to preserve higher values and is narrowly tailored to serve that interest.” Bernstein v.

Bernstein Litowitz Berger & Grossmann LLP, 814 F.3d 132, 144 (2d Cir. 2016) (quoting In re N.Y. Times Co., 828 F.2d 110, 116 (2d Cir.1987)). No protective order shall be submitted that provides for sealing of documents or other information in connection with a submission to the Court, except following a motion supported by competent evidence showing that sealing is essential to preserve higher values and is narrowly tailored to serve that interest. All protective orders shall comply with this entire Rule 4, and are subject to ongoing review and reexamination by the Court.

B. Filing Materials under Seal. Notwithstanding any protective order, any party seeking to file materials under seal (whether as part of a motion, a pretrial filing, or other submission) is required to move for permission to file the materials under seal contemporaneously. The party shall do so according to the following procedures.

i. The party shall file the notice of motion and redacted versions of the briefing and any supporting materials on ECF, together with an unredacted copy to Chambers, specifying those portions sought to be sealed and setting forth the reasons why sealing is appropriate under the circumstances. For exhibits over 100 cumulative pages, the party shall submit the unredacted documents to Chambers by CD only.

5. Settlements. In the case of settlements, requests that the Court retain jurisdiction will be considered only if all documents relating to the settlement are exhibited to the Court for review and further instructions, which may include requiring the parties to file all such documents and make them publicly accessible.

6. Notice for Collective Action Lawsuits. Parties moving the Court to approve a collective action notice shall use the template attached.

Sept 11th Rules

CHAMBERS RULES FOR SEPTEMBER 11 CONSOLIDATED CASES

Counsel are referred to Judge Hellerstein’s Individual Rules. Judge Hellerstein’s Rules apply to the September 11 Consolidated Cases except to the extent altered or supplemented by the following rules.

Counsel Communication with the Court

A. Telephone Communication. Except for good cause, only Liaison Counsel may contact Chambers by telephone.

B. Facsimile Communication.

i. Written communications of six (6) pages or fewer may be faxed at any time without permission. No hard copy should be sent if a copy is sent by facsimile.

ii. Written communications of six (6) to twenty (20) pages may be faxed, without permission, only after hours: after 5:30 P.M through 8:30 A.M. the following morning. During office hours, between 8:30 A.M. and 5:30 P.M., permission to fax 6- to 20-page documents is necessary. No hard copy should be sent if a copy is sent by facsimile.

iii. Written communications of twenty-one (21) pages or more may only be faxed with permission. Permission is likely to be granted only in urgent circumstances. No hard copy should be sent if permission is given to fax the document.

C. Hand Deliveries. Permission for all hand deliveries to chambers remains necessary.

D. Courtesy Copies.

i. Courtesy copies of all documents filed with the Court should be forwarded in hard copy by mail to Chambers.

ii. A courtesy list of all newly-filed actions is requested, and should be sent by facsimile.

E. Docketing. Docket numbers must appear on all submissions to the Court. Thus far, the September 11 cases have been consolidated under the following master docket numbers:

i. In re September 11 Litigation, 21 MC 97 (AKH). Claims brought by passengers and ground victims of the September 11 attacks.

Last Updated 12/6/2006 ii. In re September 11 Litigation, 21 MC 101 (AKH). Claims brought by property owners whose property was damaged as a result of the September 11 attacks.

iii. In re World Trade Center Disaster Site Litigation, 21 MC 100 (AKH) Claims brought by those who came to the World Trade Center disaster site to assist with the debris removal effort following the September 11 attacks.

iv. In re World Trade Center Disaster Site Litigation, 21 MC 102 (AKH) Claims brought by those who assisted with the debris removal effort at sites other than the WTC site following the September 11 attacks.

v. If a filing relates to all of the cases within a group, the master caption should be used. If a filing relates to specific case, the individual docket number and the master docket number should appear on the filing.

Court Communication with Counsel

A. Phone calls and facsimiles from the Court will be made to Liaison Counsel only, unless otherwise necessary.

B. Certain orders and notices will be posted on the Southern District web site for the September 11 litigation: http://www.nysd.uscourts.gov/Sept11Litigation.htm

C. The Court has set up an email address (wtc_letters@nysd.uscourts.gov) to communicate to counsel in the September 11 litigation. Counsel should not, however, respond by email to the Court.

Liaison Counsel Contact Information

A. In re September 11 Litigation, 21 MC 97 (AKH)

i. Plaintiff Liaison Counsel: Marc Moller, Kreindler & Kreindler, 100 Park Avenue, New York, NY 10017. Telephone: 212-687-8181. Fax: 212- 972-9432.

ii. Defense Liaison Counsel: Desmond Barry, Condon & Forsyth, 7 Times Square, New York, NY 10036. Telephone: 212-894-6770. Fax: 212-894-

B. In re September 11 Litigation, 21 MC 101 (AKH)

i. Plaintiff Liaison Counsel: Bob Clifford & Tim Tomasik, Clifford Law Offices, 312-899-9090

Last Updated 12/6/2006 ii. Desmond Barry, Condon & Forsyth, 7 Times Square, New York, NY 10036. Telephone: 212-894-6770. Fax: 212-894-6771.

C. In World Trade Center Disaster Site Litigation, 21 MC 100 (AKH)

i. Plaintiff Liaison Counsel: Paul Napoli, Worby, Groner, Napoli & Bern, 212-267-3700.

ii. Defense Liaison Counsel: James Tyrrell & Joseph Hopkins, Patton Boggs, 973-848-3930.

D. In World Trade Center Disaster Site Litigation, 21 MC 102 (AKH)

i. Plaintiff Liaison Counsel: Bob Grochow, Robert Growchow Law Office, 212-233-5400; Gregory Cannata, Law Firm of Gregory Cannata, 212-553- 9206.

ii. Defense Liaison Counsel: James Tyrrell & Joseph Hopkins, Patton Boggs, 973-848-3930.

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