Parties to Court: Give Us Another 60 Days

The following is the text of plaintiffs' counsel Michael Boni's April 27 letter to Judge George B. Daniels: I write on behalf of all parties and objectors, in response to Your Honor's request for a status update. As Your Honor knows, the Second Circuit ruled last August 2011 not to affirm this Court's approval of the amended settlement. After the appellees' motions for rehearing were denied in November 2011, the parties and the objectors' counsel have been negotiating under the supervision of mediator Ken Feinberg, in an attempt to reach a global resolution of this matter. The talks have accelerated since March 14, 2012, when the parties and objectors' counsel had a mediation session at Mr. Feinberg's New York offices. Although significant progress has been made, the mediation has been difficult, and some more time is needed before we will be in a position to bring a settlement to the Court's attention. We will, of course, notify the Court of any settlement developments as soon as they arise, and propose that in any event we update this status report in no more than sixty days. If the Court wishes a report sooner than that, we are available at the Court's convenience to provide it.