CaSe Document 68 Filed 07/13/15 Page 1 of 3
US. Department of Justice -

 

United States Attorney
Southern District of New York

 

 

 

 

 

 

 

 

 

 

 

 



 
   

 

nsoc anY 
DOCUM States Digit-tot Courthouse
I igL?lL?l  I. . duv 3.3L. 
gag- I Write Plains. New York1060}
- - Iune- so 2015 
EX PARTE AND UNDER SEAL . 
Application Granteda??en? 
BY HAND So Ordered. 
Honorable Cathy Seibel I  7' -   
United States District Judge   new

 

300 Quarropas Street
White Plains, New York 10601

Cathy Seihel, A,  
@Wna

 

{if mama-am

Re: Reimer v. Town of Ramapo et 21., 14 Civ. 7044 (CS) 

I  Dear Judge Seibel:

On February 4, 2015, the Court granted the Government?s motions to intervene in
the above-referenced civil action and to stay discovery of audio recordings (the ?Recordings?) in
the plaintiff possession while the Government continued its parallel criminal and civil
investigations of this matter. On April 30, 2015, the Government moved that the stay be

     
 

extended until the completion of its investigation for an audio recording dated
and for an additional 60 days for the other recordings. On May 1, 2015, the Court extended the
stay of discovery for 60 days for all the recordings and further ordered that the Government
report back to the Court regarding its motion for a ?nther stay of discovery of the  

recording at the end of the sixty day period.

 
 

 

  

The Government now moves that the Court stay discovery of th  
recording for an additional 90 days, during which time the Government anticipates 1t W111
complete its investigation and make charging decisions in this matter. The Government has no
objection to the production of the other recordings at this time.

Since the Court issued its May 1 order the has continued to pursue

iti?f'?stigati us. For eXarnple, 

    

 

 

 

  Case Document 68 Filed 07/13/15 Page 2 of 3
 Honorable Cathy Seibel

June 30, 2015
Page 2 of3

 

    
   
      

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reason for a stay 0

 

 

  

113ch 11.11;, 1.0 and WIN thei 1; and o?mers,? defenses to the 
3001'. I

    

It; in that. and subjem potential Witnesses who were

in noccnt pm?tie'ilimn15 in lhc: l't?ii?i'titfd to 11:: 6: risk of ii'liimidaiion 01' suboma?tion of

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  y. I. lfi?if;
3.4Case Document 68 Filed 07/13/15 Page 3 of 3
Honorable Cathy Seibel
June 30, 2015
Page 3 of3

 

 

 

this 

 

 

consents to the stay of discovery with respect to the  I ecording on the condition that

  

the general stay of discovery in this case stays in effect  - ays.
Accordingly, the Govermnen ecIy requests that the Court extend the
previously ordered stay on discovery of the  ecording for an additional 90-day

period. Since this letter refers to ongoing criminal and civil investigations, We 

request that it be ?led under seal. 

  

 

Respectfully submitted,

PREET BHARARA
United States Attorney

by:  
Douglas B. Bloom 
James McMahon
Assistant United States Attorneys
(914) 993-1934/1936