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

Filing 4237

LETTER addressed to Judge Shira A. Scheindlin from JAMES A. PARDO dated 7/20/15 re: Defendants Pre-Conference Letter for July 28, 2015 Status Conference. Document filed by Exxon Mobil Corporation(formerly known as Exxon Corporation doing business as Exxon Mobil Refining and Supply Company, doing business as Exxon Chemical U.S.A formerly known as Exxon Mobil Chemical Corporation,). (Attachments: # 1 JOINT AGENDA)(Pardo, James)

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Boston Brussels Chicago Düsseldorf Frankfurt Houston London Los Angeles Miami Milan Munich New York Orange County Paris Rome Seoul Silicon Valley Washington, D.C. Strategic alliance with MWE China Law Offices (Shanghai) James A. Pardo Attorney at Law +1 212 547 5353 July 20, 2015 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: Master File C.A. No. 1:00-1898 (SAS), M21-88, MDL No. 1358 Defendants’ Pre-Conference Letter for July 28, 2015 Status Conference Dear Judge Scheindlin: Defendants respectfully submit this letter in advance of the July 28, 2015 conference. JOINT AGENDA ITEM I. Commonwealth of Pennsylvania: Report on CMO Negotiations The parties are continuing to meet and confer regarding a joint proposed CMO. Defendants will provide the Court with an update on those discussions in their reply letter. PLAINTIFFS’ AGENDA ITEM I. Commonwealth of Puerto Rico I & II: Implications of Post-Fraguada Development in Puerto Rico Law On July 14, Plaintiffs submitted a letter to the Court indicating that they had discovered a number of post-Fraguada cases allegedly impacting certain of the Court’s prior rulings on statute of limitations. As also indicated in that letter, Plaintiffs discussed these cases – and their alleged implication – in opposition to the motion for summary judgment of certain Shell defendants. See Ltr. from S. Kauff to Court (July 14, 2015), at 1 n.1. Therefore, the moving Shell entities will timely respond to Plaintiffs’ new arguments in their reply brief, which is due Friday, July 24. In the interim, it is sufficient to say that Defendants disagree that these cases would have had any impact on the Court’s prior decisions or that they demonstrate a U.S. practice conducted through McDermott Will & Emery LLP. 340 Madison Avenue New York New York 10173-1922 Telephone: +1 212 547 5400 Facsimile: +1 212 547 5444 The Honorable Shira A. Scheindlin July 20, 2015 Page 2 “development” in Puerto Rico law. Defendants will be ready to address this issue with the Court on July 28 should the Court have any questions. *** As always, we appreciate your Honor’s attention to this matter and ask that this letter be docketed by the Clerk’s Office so that it is part of the Court’s file. Sincerely, James A. Pardo James A. Pardo cc: All Counsel of Record by LNFS, Service on Plaintiffs’ Liaison Counsel

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