In Re: Methyl Tertiary Butyl Ether ("MTBE") Products Liability Litigation

Filing 3977

ENDORSED LETTER addressed to Judge Shira A. Scheindlin from James A. Pardo dated 4/16/2014 re: Both sides respectfully request a 45-day extension of the May 15 deadline for the CMO 4 and CMO 10 discovery. ENDORSEMENT: The parties' request for an extension is hereby GRANTED. The CMO 4 and CMO 10 discovery deadline is now June 30, 2014. SO ORDERED. (Signed by Judge Shira A. Scheindlin on 4/18/2014) Filed In Associated Cases: 1:00-cv-01898-SAS-DCF, 1:13-cv-07247-SAS, 1:13-cv-07271-SAS, 1:13-cv-07272-SAS, 1:13-cv-07299-SAS(ft)

McDermott
Will ,, Emery
Boston Brussels Chicago DOsseldort Frankfurt Houston London Los Angeles Miami

\

.

ar o

Milan Munich New York Orange County Paris Rome Seoul Silicon Valley Washington, D.C.

Attorney at Law
jpardo@mwe com

Strategic alliance with MWE China Law Offices (Shanghai)

[phone]

The rod1 e~I rt?qv.es+- ~ (\/Yl

April 16, 2014

,~ ltt~'l"t'bJ GR Af01t D

BY HAND DELIVERY AND ELECTRONIC MAIL
The Honorable Shira A. Scheindlin
United States District Judge
Southern District of New York
Daniel Patrick Moynihan Courthouse
500 Pearl Street, Room 1620
New York, New York 10007-1312
Re:

CVV\O lO
V°)CJ'tV

cl\slov£·r'j ~o..cU1t\{

so

The parties are actively engaged in settlement talks, with much progress being made. But
both sides also face a May 15 deadline to provide CMO 4 and CMO 10 discovery - productions
that would require very significant resources over the next month. I have conferred with Mr.
Gordon, Mr. Summy and Ms. Greenwald, and we are all agreed that both sides would prefer to
devote their resources to continued settlement efforts. Accordingly, both sides respectfully
request a 45-day extension of the May 15 deadline for the CMO 4 and CMO 10 discovery.
As always, we appreciate your time and attention to this matter.

Respectfully submitted,
/

I')

ORDcK-eD:

Master File C.A. No. 1:00-1898 (SAS), M21-88, MDL No. 1358

r\/ 8/f

(A/nd.

}u..t1e?>0 1 201~.

I write on behalf of Defendants and Plaintiffs in the four MTBE cases filed last year. 1

~-

t~"(\

lhe ( WIO '-/

Dear Judge Scheindlin:

r//rv:/:11,(j:) •_

f'--A-k/i'J5

/

t/rvZ?k

James A. Pardo
cc: All Counsel of Record by LNFS, Service on Plaintiffs' Liaison Counsel
1

Town of Brewster, et al. v. Atlantic Richfield Co., et al., No. 13-cv-0724 7; Town of Hinesburg
v. Atlantic Richfield Co., et al., No. l 3-cv-07271; City of Manning v. Ashland Inc., et al., No. l 3cv-07272; and City of Portageville v. Ashland, Inc., et al., No. 13-cv-07299.

U.S. practice conducted through McDermott Will & Emery LLP.

340 Madison Avenue New York New York 10173-1922 Telephone: [phone] Facsimile: [phone] www.mwe.com