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

Filing 4632

LETTER MOTION for Leave to File Excess Pages addressed to Judge Vernon S. Broderick from Joseph L. Sorkin dated September 29, 2021. Document filed by Lukoil North America LLC, Lukoil Pan Americas, LLC, PJSC LUKOIL.Filed In Associated Cases: 1:00-cv-01898-VSB, 1:14-cv-06228-VSB-DCF.(Sorkin, Joseph)

JOSEPH L. SORKIN
+1 212.872.7464/fax: [phone]
[e-mail]

September 29, 2021

Honorable Vernon S. Broderick
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
Re:

Request to Expand Page Limit in MDL 1358 / MTBE, In Re: Methyl Tertiary
Butyl Ether (“MTBE”) Products Liability Litigation, No. 1:00-cv-01898-VSB

Dear Judge Broderick:
Defendants PJSC LUKOIL, LUKOIL Pan Americas, LLC, and LUKOIL North America
LLC (collectively, the “Remaining LUKOIL Defendants”) respectfully request that this Court
expand the word limit for the memorandum of law in support of their motions to dismiss to be
filed on October 1, 2021. Rather than submit three separate memoranda in support of their
motions, the Remaining LUKOIL Defendants are planning to submit one memorandum of law
that addresses each of their separate arguments in support of their motions to dismiss. The
Remaining LUKOIL Defendants have endeavored to be as concise as possible, but require pages
in excess of the 25-page limit required by this Court’s Rule 4.B. Accordingly, the Remaining
LUKOIL Defendants respectfully request leave to file a memorandum of law of no more than 40
pages.
The Commonwealth does not object to the Remaining LUKOIL Defendants’ request to
exceed the Court’s page limit, so long as the Commonwealth is provided a reciprocal number of
pages for its opposition to the Remaining LUKOIL Defendants’ consolidated motion. The
Remaining LUKOIL Defendants consent to providing the Commonwealth a reciprocal number
of pages for its opposition.
The Remaining LUKOIL Defendants and the Commonwealth have also conferred about
a briefing schedule for the Remaining LUKOIL Defendants’ motions to dismiss and would
propose that the Court adopt the following schedule:

One Bryant Park | New York, New York 10036-6745 | 212.872.1000 | fax: [phone] | akingump.com

Honorable Vernon S. Broderick
United States District Court
Southern District of New York
September 29, 2021
Page 2
Remaining LUKOIL Defendants’ Motion to Dismiss:
Commonwealth’s Opposition:
Remaining LUKOIL Defendants’ Reply:

Friday, October 1, 2021
Friday, January 14, 2022
Friday, February 18, 2022

Respectfully Submitted,

/s/ Joseph L. Sorkin