Home/Source documents/Stay, State of New York et al. v. U.S. Department of Education, No. 1:25-cv-02990 (S.D.N.Y.), Doc. 136 (November 13, 2025)
Stay, State of New York et al. v. U.S. Department of Education, No. 1:25-cv-02990 (S.D.N.Y.), Doc. 136 (November 13, 2025)
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Case 1:25-cv-02990-ER Document 136 Filed 11/13/25 Page 1 of 2
Office of the New York State Letitia James
Attorney General Attorney General
November 13, 2025
By ECF
The Honorable Edgardo Ramos
United States District Court
Southern District of New York
Thurgood Marshall United States Courthouse
40 Foley Square
New York, NY 10007
Re: State of New York, et al. v. U.S. Dep’t of Education, et al., Case
No. 25-cv-2990 (ER) (BCM)
Dear Judge Ramos:
This Office represents the State of New York in the above-referenced action. We write to
report that the parties have come to an agreement that they hope will allow for final resolution of
the case without further litigation. On behalf of all parties, we respectfully submit this joint letter
motion to request that the Court “so order” the attached Stipulation and [Proposed] Order Staying
Case attached as Exhibit A (“Stipulation”).
As detailed in the Stipulation, Defendants agree to: (i) refrain from rescinding the
previously-approved liquidation extensions; (ii) use their reasonable, good faith efforts to resolve
pending and future payment requests within the time periods prescribed in the Stipulation; and (iii)
allow vendor contracts that had not expired as of March 28, 2025 to be extended for up to 67 days
to make up for the period between Defendants’ March 28 rescission letter and the Court’s June 3
preliminary injunction order during which Plaintiffs could not make use of their contractors’
services. The parties have further agreed that the case shall remain stayed so long as Defendants
abide by these undertakings, and that Plaintiffs shall voluntarily dismiss the case with prejudice
once all of payment requests submitted through the expiration of Plaintiffs’ extended liquidation
periods have been determined and processed by Defendants.
The Capitol, Albany NY 12224 | 1-800-771-7755 | Fax 518-650-9401 | ag.ny.gov
Case 1:25-cv-02990-ER Document 136 Filed 11/13/25 Page 2 of 2
Hon. Edgardo Ramos
November 13, 2025
Page 2
The parties accordingly jointly submit to be “so ordered” by the Court the Stipulation
setting forth the terms of their agreement and staying the case subject to the agreed-on conditions.
The parties appreciate the Court’s consideration of this request to resolve the case in accordance
with the terms of the Stipulation.
Respectfully,
/s/ Andrew Amer
Andrew Amer
Special Counsel
Andrew.amer@ag.ny.gov
(212) 416-6127
cc: Counsel of Record (via ECF)
The Capitol, Albany NY 12224 | 1-800-771-7755 | Fax 518-650-9401 | ag.ny.gov