1:25-cv-02247
S.D.N.Y.
Apr 14, 2025

Ti Goodwin v. Oren Alexander

Case 1:25-cv-02247-PAE

United States District Court Southern District of New York

April 14, 2025

17 State Street
39th Floor
New York, NY 10004

Office 212-232-2500
Fax 212-232-2509

TorganCooperAaron.com

ATTORNEYS AT LAW
EVAN TORGAN
EDWARD T. COOPER
MITCHELL K. AARON
JONATHAN TABAR
BRENDAN BROWN
MITCHELL R. DRACH
Of Counsel

April 14, 2025

Via ECF & EMAIL
Hon. Paul A. Engelmayer
United States District Judge
Southern District of New York
500 Pearl Street
New York, New York 10007
EngelmayerNYSDChambers@nysd.uscourts.gov

Re: Ti Goodwin v. Oren Alexander, 25-CV-2247 (PAE)
Joint Request to Stay Proceedings.

Your Honor:

We write jointly on behalf of all parties pursuant to the Court‘s Order dated March 19, 2025, which directed the parties to submit a Civil Case Management Plan and Scheduling Order, as well as a joint letter, in advance of the initial pretrial conference currently scheduled for April 16, 2025, at 2:00 p.m.

By way of background, this matter involves a cause of action under the Victims of Gender-Motivated Violence Protection Law (“VGMVPL“), N.Y.C. Admin. Code § 10-1101 et seq. Plaintiff alleges that she was surreptitiously drugged and subsequently raped after meeting Defendant Oren Alexander (“Defendant“) at a Gotham Magazine party on February 13, 2011.

Defendant denies these allegations and contends that the action is time-barred and preempted by New York State‘s Child Victims Act (“CVA“) and Adult Survivors Act (“ASA“). Defendant also anticipates filing a motion pursuant to Federal Rule of Civil Procedure 12(b) seeking dismissal of the Complaint with prejudice.

In light of the evolving legal landscape relevant to the claims at issue in this matter, the parties respectfully request that the Court stay the proceedings for a period of six (6) months. Specifically, we ask that the Court adopt the same approach it recently employed in Willett v. Alexander, No. 24-CV-05672 (NRB) and Laura Buck v. Tal Alexander, et al., No. 25-CV-2112 (NRB), and stay this action pending developments in related appellate proceedings.

As Your Honor may be aware, two cases currently pending before the United States Court of Appeals for the Second Circuit—Parker v. Alexander, No. 24 Civ. 4813 (LAK), 2025 WL 268436 (S.D.N.Y. Jan. 22, 2025), and Doe v. Black, No. 23 Civ. 6418 (JGLC), 2024 WL 4335453 (S.D.N.Y. Sept. 27, 2024)—raise substantially similar legal questions to those presented by Defendants in this matter. The Second Circuit‘s resolution of those appeals is likely to be dispositive or, at minimum, instructive with respect to the central issues in this case.

Accordingly, in the interest of judicial economy and to avoid potentially unnecessary motion practice, the parties respectfully request that the Court enter an informal stay of all deadlines and proceedings in this matter for a period of at least six months, or until further direction is received from the Court following resolution or clarification from the Second Circuit.

We thank the Court for its attention to this matter and are available to provide any additional information the Court may find helpful.

Respectfully submitted,

Evan Torgan
TORGAN COOPER & AARON, P.C.
17 State Street, 39th Floor
New York, New York 10004
Tel.: 212-232-2500

Attorney(s) for Plaintiff Ti Goodwin

Jason Goldman
LAW OFFICES OF JASON GOLDMAN
275 Madison Avenue, 35th Floor
New York, New York 10016
Tel.: 212-466-6617

Counsel for Defendant Oren Alexander

GRANTED. This case is hereby stayed pending the Second Circuit decisions in Parker v. Alexander, No. 24 Civ. 4813 (LAK), 2025 WL 268436 (S.D.N.Y. Jan 22, 2025), and Doe v. Black, No. 23 Civ. 6418 (JGLC), 2024 WL 4335453 (S.D.N.Y. Sept. 27, 2024). The parties are to jointly file a status update no later than two weeks after the date of each decision.

SO ORDERED.

PAUL A. ENGELMAYER

United States District Judge

April 14, 2025
New York, New York