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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 

May 14, 2024 Order (ECF No. 191). 

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. 

2. On May 13, 2024, the Parties filed a Joint Status Report (ECF No. 190) informing 

the Court that a settlement agreement was drafted between counsel for the Plaintiffs and the City, 

and the City Commission was briefed. The Parties also informed the Court that a Resolution to 

approve the settlement (the “Resolution”) was set on the City Commission agenda for the 

May9, 2024. City Commission meeting; however, the City Commission deferred the item to the 

next meeting, on May 23, 2024, based upon the absence of Commissioner Damian Pardo. 

Case 1:22-cv-24066-KMM Document 193 Entered on FLSD Docket 05/24/2024 Page 1 of 4
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3. The Parties further informed the Court that they anticipated the settlement would 

be approved at 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; and that they would be able to 

provide the Court a status report on May 24, 2024, following the May 23, 2024, Commission 

meeting (ECF No. 190). 

4. The Parties also informed the Court that the City filed a notice of appeal on May 

10, 2024 (ECF No. 189), but the filing of the appeal did 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. 

5. In that same Joint Status Report (ECF No. 190), the Parties requested the Court to 

stay the briefing and hearing proceedings set forth in its April 15, 2024 Order (ECF No. 186). 

6. On May 14, 2024, the Court entered an order staying and continuing the deadlines 

and hearing set forth in (ECF No. 186) until after the May 23, 2024 Commission meeting. (ECF 

No. 191) The Court further ordered the Parties to file a joint status report with the Court on or 

before May 24, 2024. (ECF No. 191) 

9. On May 23, 2024, the City Commission met and approved the Resolution by a four 

to one vote. The Mayor’s ten-day veto period will expire on June 2, 2024. If not vetoed, or if 

approved by the Mayor earlier, then the Resolution will go into effect. If vetoed, that veto may be 

overridden by a vote of four of the Commissioners. When the Resolution is effective, the parties 

can execute the settlement agreement. The parties therefore request that this Court continue to 

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abate this case until the parties can submit the settlement to this Court for approval and execution 

of a proposed consent judgment. 

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 the Court continue the stay in this action. 

Respectfully submitted this 24th 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 

neil.steiner@dechert.com 

Christopher J. Merken* 

Dechert LLP 

Cira Centre 

2929 Arch Street 

Philadelphia, PA 19104 

(215) 994-2380

/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 

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

Case 1:22-cv-24066-KMM Document 193 Entered on FLSD Docket 05/24/2024 Page 3 of 4
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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

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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