Anwar et al v. Fairfield Greenwich Limited et al

Filing 1150

ENDORSED LETTER addressed to Magistrate Judge Frank Maas from Bradley P. Smith dated 6/10/2013 re: We write on behalf of the Standard Chartered Defendants ("Standard Chartered") to request a conference with the Court concerning expert discovery. ENDORSEMENT: The Court will hold a telephone conference on 6/14/13 at 3pm. If this date and time are not convenient, counsel should place a conference call to chambers by noon on 6/13 to reschedule., ( Telephone Conference set for 6/14/2013 at 03:00 PM before Magistrate Judge Frank Maas.) (Signed by Magistrate Judge Frank Maas on 6/10/2013) (lmb) (Additional attachment(s) added on 6/11/2013: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C) (lmb).

Exhibit C

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
Master File No. 09-CV-llS (VM)

PASHA ANWAR, et aL,
Plaintiffs,

v.
FAIRFIELD GREENWICH LIMITED,
et aL,
Defendants.
This document relates to:

The Standard Chartered Cases
STANDARD CHARTERED PLAINTIFFS'

RESPONSE TO REQUESTS FOR PRODUCTION

RE ROBERT A. PICARD AND GEORGE A. MARTIN

The Standard Chartered Plaintiffs ("Plaintiffs") hereby respond to the
Standard Chartered Defendants' First Sets of Requests for Production of
Documents Concerning Robert A. Picard and George A. Martin, respectively
("RFP").

Objections to Promulgation of the RFPs
The Plaintiffs object to the RFPs on the following grounds:
L

that they were submitted after the end of the discovery period

without obtaining leave of court to institute this discovery;
2.

that the pretrial order, which governs expert-related discovery,

does not authorize requests for production under Fed.R.Civ.P. 34 but permits

a request under Rule 34 to obtain otherwise unobjectionable documents;
3.

that the RFPs were submitted in bad faith and with the purpose

of delay and obfuscation; and
4.

that the RFPs impose undue burdens on the Plaintiffs.

The Plaintiffs expressly reserve the right to assert additional
objections to the individual requests if the Court rules that the RFPs are not
to be stricken.

Richard E. Brodsky
The Brodsky Law Firm, PL
200 South Biscayne Blvd., Suite 1930
Miami, FL 33131
[e-mail]
Tel: [phone]
Fax: [phone]
Attorney for Maridom Plaintiffs
Member, Standard Chartered Plaintiffs'
Steering Committee
On behalfof the Standard Chartered
Plaintiffs
Admitted pro hac vice

THE BRODSKY L.\wFlRM. PL· 200 S. BISCAYNE BLm., SUITE 1930· MIAMl. FL. 33131·786·220-3328

2