Exhibit,Appendix: Uber Technologies, Inc. v. New York City Department Of Consumer And Worker Protection, Vilda Vera Mayuga in her official capacity as Commissioner of the New York City Department of Consumer and Worker Protection, The City Of New York

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                                FILED: NEW YORK COUNTY CLERK 07/06/2023 10:16 AM         INDEX NO. 155943/2023
NYSCEF DOC. NO. 17                                 RECEIVED NYSCEF: 07/06/2023




                        Exhibit 15
FILED: NEW YORK COUNTY CLERK 07/06/2023 10:16 AM                                             INDEX NO. 155943/2023
NYSCEF DOC. NO. 17                                                                   RECEIVED NYSCEF: 07/06/2023




      (202) 223-7308

      (202) 379-4217

      kdunn@paulweiss.com




                                                  November 23, 2022




              TO: John DeVito
              JDeVito@Dcwp.nyc.gov

              Freedom of Information Officer
              NYC Department of Consumer and Worker Protection (DCWP)
              42 Broadway, 8th floor
              New York, NY 10004

              I write to follow up on the records request (FOIL-2022-866-00337) submitted on July 14,
              2022 (the “Request”). The Request sought documents relating to a survey the
              Department of Consumer and Worker Affairs (the “Department”) announced it was
              conducting in its June 14, 2022 press release (the “Survey”).

              On July 21, 2022 the Department acknowledged receipt of the Request and indicated it
              would take “approximately four (4) months to complete” (i.e., by November 21, 2022).
              Four months have now passed, and the Department has not responded to the Request with
              a single responsive document.

              According to the City’s FOIL request website, the Department, at some point,
              significantly extended its estimate of the time to respond to the Request from four months
              to February 16, 2023—more than seven months after the Request was made.

              The completion date of any Freedom of Information request must “be reasonable under
              the circumstances of the request.” N.Y. Pub. Off. Law § 89(3)(a). Given the rulemaking
              process in which the Department is now engaged and that the current time estimate is
              nearly double the Department’s initial estimate, the current estimate proposed by the
              Department does not appear to be reasonable under the circumstances of the request.

              On November 16, 2022, the Department released a Proposed Rule to implement Local
              Law 115 of 2021 (the “DCWP Minimum Pay Rule”) based in part on the Survey and
              announced a public hearing will be held on Friday, December 16, 2022. The
FILED: NEW YORK COUNTY CLERK 07/06/2023 10:16 AM                                             INDEX NO. 155943/2023
NYSCEF DOC. NO. 17                                                                    RECEIVED NYSCEF: 07/06/2023



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             Department’s estimated date for responding to the Request would prevent commenters
             from reviewing the requested materials, and from providing timely comments on the
             DCWP Minimum Pay Rule based on that review. It remains critical that the requested
             materials be provided immediately. They are essential for the public to understand, prior
             to the public hearing date and the effective date of any adopted rule, the Department’s
             rulemaking process, and the Department’s assessment of the DCWP Minimum Pay
             Rule’s likely and intended effects.

             I request that the documents be provided immediately so that they may be reviewed in
             advance of the public hearing date.

             We ask that you please confirm that the requested records will be provided within this
             reasonable requested timeframe. If you do not believe the requested timeframe to be
             reasonable under the circumstances, please explain why. We request that the Department
             please provide its position on the matters raised in this letter within a week (i.e., by
             November 30, 2022).



                                                                         Sincerely,

                                                                         /s/ Karen L. Dunn

                                                                         Karen L. Dunn