Anwar et al v. Fairfield Greenwich Limited et al

Filing 1123

ENDORSED LETTER addressed to Judge Victor Marrero from Richard E. Brodsky dated 4/22/2013 re: The Maridom Plaintiffs respectfully submit that no prejudice will be caused the Defendants were the Court to grant leave to amend now and that no meaningful delay will be caused by permitting an amendment. Moreover, with the substantially streamlined proposed amendment, the burden on the Defendants will be even less than what would have been caused if the original amendment had been permitted. In the words of Rule 15(a), the Court should "freely" grant the proposed amendment precisely because "justice" so plainly requires it. ENDORSEMENT: The Clerk of Court is directed to enter into the public record of this action the letter above submitted to the Court by the Maridom Plaintiffs. So Ordered. (Signed by Judge Victor Marrero on Richard E. Brodsky) (js) (js).

From

Rtvero Mestre

RIVERO MESTRE

April 23, 2013

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Honorable Victor Marrero
United States District Judge
Daniel Patrick Moynihan U.S. Courthouse
500 Pearl Street
New York. New York 10007-1312
Re:

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Anwar, et aL v. Fairfield Greenwich Limited, et at.,

Dear Judge Marrero:
I write on behalf of Plaintiff Headway Investment Corp. with respect to our April
22,2013 letter to the Court requesting a pre-motion conference to permit Headway's

filing of a motion to amend its complaint. Attached as composite Exhibit A to that letter
were two declarations from former Standard Chartered employee Sebastian Gonzalez.
After we served our letter on all parties, counsel for the Standard Chartered Defendants
(the ''"Bank'') contacted us, asking us to contact chambers and request that the clerk not
immediately file the declarations, because the Bank intended to designate them
"confidential," pursuant to the February 4,2011 Stipulation and Order Govenling
Confidentiality of Discovery Material (the "Confidentiality Order"). The declarations are
not confidentiaL Headway objects to and opposes the Bank's attempt to designate them
confidential. That said, we advised the Bank's counsel that Heachvay would agree to
contact the Court, and by this letters we request that Exhibit A to Headway's April 22,
2013 letter not be entered into the public record until the parties have briefed the
question, and the Court has had a chance to evaluate the Bank's designation request.
Headway reserves all rights, including those arising from the Confidentiality Order.
Respectfully submitted,

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Counsel for all parties (by e-mail)

1460.0l\CORRES\LTR 1. MARRERO ()4,23.13

Rivero Mestre LL~)
www.riverQmestre.com
T30544525DO
F30S 4452505

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