cuomo, favors v. cuomo case

STATE OF NEW YORK OFFICE OF THE ATTORNEY GENERAL ERIC T. SCHNEIDERMAN ATTORNEY GENERAL KENT T. STAUFFER EXECUTIVE DEPUTY ATTORNEY GENERAL DIVISION OF STATE COUNSEL JUNE DUFFY ASSISTANT ATTORNEY GENERAL IN CHARGE LITIGATION BUREAU April 27, 2012 VIA ECF FILING AND HAND DELIVERY The Honorable Gerard E. Lynch United States Court of Appeals for the Second Circuit 40 Foley Square New York, NY 10007 The Honorable Reena Raggi United States Court of Appeals for the Second Circuit 40 Foley Square New York, NY 10007 The Honorable Dora L. Irizarry United States District Court Eastern District of New York 225 Cadman Plaza East Brooklyn, New York 11201 Re: Favors v. Cuomo, et al., Case No. 11-Civ.-5632 (DLI-GEL-RR) (RLM) Dear Judges Irizarry, Lynch and Raggi: I write pursuant to this Court’s Order of April 20, 2012, that Defendants show cause as to why they should not be required to identify the persons who drew the map currently being challenged by intervenor-plaintiffs in this action or make such persons available for depositions. Defendants Cuomo and Duffy played no role in drawing the lines on the challenged map, nor did anyone on their staffs. Thus, Defendants Cuomo and Duffy have no names of individuals that they can identify or make available for depositions. Nor do Defendants Cuomo and Duffy have any documents in their possession, custody, or control responsive to the Drayton Intervenors’ proposed document requests. Case 1:11-cv-05632-DLI-RR-GEL Document 329 Filed 04/27/12 Page 1 of 2 PageID #: 5953

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STATE OF NEW YORK

OFFICE OF THE ATTORNEY GENERAL

ERIC T. SCHNEIDERMAN ATTORNEY GENERAL

KENT T. STAUFFER EXECUTIVE DEPUTY ATTORNEY GENERAL

DIVISION OF STATE COUNSEL

JUNE DUFFY ASSISTANT ATTORNEY GENERAL IN CHARGE

LITIGATION BUREAU

April 27, 2012 VIA ECF FILING AND HAND DELIVERY The Honorable Gerard E. Lynch United States Court of Appeals for the Second Circuit 40 Foley Square New York, NY 10007

The Honorable Reena Raggi United States Court of Appeals for the Second Circuit 40 Foley Square New York, NY 10007

The Honorable Dora L. Irizarry United States District Court Eastern District of New York 225 Cadman Plaza East Brooklyn, New York 11201

Re: Favors v. Cuomo, et al., Case No. 11-Civ.-5632 (DLI-GEL-RR) (RLM) Dear Judges Irizarry, Lynch and Raggi:

I write pursuant to this Court’s Order of April 20, 2012, that Defendants show cause as to why they should not be required to identify the persons who drew the map currently being challenged by intervenor-plaintiffs in this action or make such persons available for depositions.

Defendants Cuomo and Duffy played no role in drawing the lines on the challenged map, nor did anyone on their staffs. Thus, Defendants Cuomo and Duffy have no names of individuals that they can identify or make available for depositions. Nor do Defendants Cuomo and Duffy have any documents in their possession, custody, or control responsive to the Drayton Intervenors’ proposed document requests.

Case 1:11-cv-05632-DLI-RR-GEL Document 329 Filed 04/27/12 Page 1 of 2 PageID #: 5953