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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

Case No. 1:22-cv-24066-KMM 

GRACE, INC., et al., 

Plaintiffs, 

v. 

CITY OF MIAMI, 

Defendant. 

________________________________/ 

JOINT STATUS REPORT 

Plaintiffs, GRACE, Inc., Engage Miami, Inc., South Dade Branch of the NAACP, MiamiDade Branch of the NAACP, Clarice Cooper, Yanelis Valdes, Jared Johnson, Alexandra Contreras 

and Steven Miro, and Defendant, City of Miami, (collectively, the “Parties”), and by and through 

the Parties’ undersigned counsel, hereby file this joint status report in accordance with this Court’s 

Order. ECF No. 188. 

1. The Parties have been negotiating in good faith toward a mutually agreeable 

resolution to this case and related litigation and believe they may have reached that resolution. 

Accordingly, they moved to stay further proceedings (ECF No. 187) and this Court granted that 

motion, directing the Parties to provide a status report by May 13, 2024 (ECF No. 188). 

2. A settlement agreement was drafted between counsel for the Plaintiffs and the City, 

and the City Commission was briefed. A Resolution to approve the settlement was set on the City 

Commission agenda for the May 9, 2024 City Commission meeting. At that meeting, 

Commissioner Damian Pardo was not present. Commissioner Joe Carollo moved to defer the item 

to the next meeting, on May 23, 2024. The City Commission agreed to defer the item. 

Case 1:22-cv-24066-KMM Document 190 Entered on FLSD Docket 05/13/2024 Page 1 of 4
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3. The Miami Herald reported that Commissioner Pardo informed them that he 

supported the settlement. Commissioners Christine King and Miguel Gabela also indicated their 

support for the settlement at the meeting. 

4. The Parties anticipate that the settlement will be approved by the May 23, 2024, 

City Commission meeting and can be executed by the Parties after the veto period expires or until 

after signed by the Mayor. 

5. The Parties anticipate being able to provide the Court with a status report following 

the May 23, 2024, Commission meeting, and request that a joint status report be due May 24, 2024. 

6. The City filed a notice of appeal on May 10, 2024 (ECF No. 189), but this does not 

indicate that it does not intend to go forward the settlement as described above. The City believes 

this appeal was necessary to preserve its appellate rights. Plaintiffs believe the City did not need 

to notice this appeal to preserve its right to appeal the interlocutory orders appealed in the notice 

of appeal, and that an appeal from a final judgment, which the Court has not yet entered, would 

encompass those interlocutory orders. The Parties agree that this appeal can be addressed by the 

settlement agreement. 

7. To avoid further expenditure of time and resources of the Court and the Parties and 

to afford the ability to focus on finalizing the mutually agreeable resolution, the Parties jointly 

request this Court continue the stay until after the May 23, 2024 Commission Meeting. 

8. Plaintiffs propose that, if the City Commission does not approve a settlement on 

May 23, 2024: 

 By May 29, 2024, Plaintiffs file the brief ordered in the Court’s Paperless Order of 

April 15 (ECF No. 186). 

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 By June 5, 2024, the City file the response ordered in the Court’s Paperless Order 

of April 15 (ECF No. 186). 

 The Court set a status hearing for the earliest practicable date after June 5, 2024. 

9. Defendant proposes that, if the City Commission does not approve a settlement on 

May 23, 2024, the Parties provide a status report to the Court by May 27, 2024, and in that report 

address the Parties’ requests regarding the need for and timing of additional briefing. 

WHEREFORE, the Parties, Plaintiffs, GRACE, Inc., Engage Miami, Inc., South Dade 

Branch of the NAACP, Miami-Dade Branch of the NAACP, Clarice Cooper, Yanelis Valdes, Jared 

Johnson, Alexandra Contreras and Steven Miro, and Defendant, City of Miami, respectfully 

provide this status report and request that this Court continue the stay in this action. 

Respectfully submitted this 13th day of May 2024. 

/s/ Caroline A. McNamara 

Nicholas L.V. Warren (FBN 1019018)

ACLU Foundation of Florida, Inc. 

1809 Art Museum Drive, Suite 203 

Jacksonville, FL 32205 

(786) 363-1769 

nwarren@aclufl.org

Daniel B. Tilley (FBN 102882) 

Caroline A. McNamara (FBN 1038312) 

ACLU Foundation of Florida, Inc. 

4343 West Flagler Street, Suite 400 

Miami, FL 33134 

(786) 363-2714 

dtilley@aclufl.org

cmcnamara@aclufl.org

Neil A. Steiner*

Julia Markham-Cameron* 

Dechert LLP 

 ree Bryant Park

1095 Avenue of the Americas 

New York, NY 10036

(212) 698-3822

/s/ George T. Levesque 

Jason L. Unger, Esquire 

Florida Bar No. 991562 

Jason.Unger@gray-robinson.com 

George T. Levesque 

Florida Bar No. 55551 

George.Levesque@gray-robinson.com 

Andy Bardos 

Florida Bar No. 822671 

Andy.Bardos@gray-robinson.com 

GRAYROBINSON, P.A. 

301 S. Bronough Street 

Suite 600 

Tallahassee, Florida 32301 

Telephone: (850) 577-9090 

Facsimile: (850) 577-3311 

Christopher N. Johnson 

Florida Bar No. 69329 

Christopher.Johnson@gray-robinson.com 

Marlene Quintana, B.C.S. 

Florida Bar No. 88358 

Marlene.Quintana@gray-robinson.com 

Fabian A. Ruiz

Case 1:22-cv-24066-KMM Document 190 Entered on FLSD Docket 05/13/2024 Page 3 of 4
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neil.steiner@dechert.com 

Christopher J. Merken* 

Dechert LLP 

Cira Centre 

2929 Arch Street 

Philadelphia, PA 19104 

(215) 994-2380 

christopher.merken@dechert.com 

Gregory P. Luib* 

Dechert LLP

1900 K Street NW 

Washington, DC 20006 

(202) 261-3413 

Gregory.luib@dechert.com 

* Admitted pro hac vice 

Counsel for Plaintiffs

Florida Bar No. 117928 

Fabian.Ruiz@gray-robinson.com 

Jessica D. Santos 

Florida Bar No. 1038776 

Jessica.Santos@gray-robinson.com 

GRAYROBINSON, P.A. 

333 S.E. 2nd Avenue, Suite 3200 

Miami, Florida 33131 

Telephone: (305) 416-6880 

Facsimile: (305) 416-6887 

CITY OF MIAMI 

GEORGE K. WYSONG, III, City Attorney 

Florida Bar No. 989010 

JOHN A. GRECO, Chief Deputy City Attorney

Florida Bar No. 991236 

KEVIN R. JONES, Deputy City Attorney 

Florida Bar No. 119067 

Office of the City Attorney

444 S.W. 2nd Avenue 

Miami, FL 33130 

Telephone: (305) 416-1800 

Facsimile: (305) 416-1801 

Counsel for Defendant

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