Anwar et al v. Fairfield Greenwich Limited et al

Filing 1316

ENDORSED LETTER addressed to Judge Victor Marrero from Richard E. Brodsky dated 9/3/2014 re: We respectfully request that this Court clarify whether the SC Plaintiffs' letter is due September 7, 2014 and whether the Court will permit that letter to be up to ten pages. ENDORSEMENT: Request GRANTED. The Court's memo-endorsed Order dated 9-3-14 is modified to extend the date by which plaintiff's herein may respond to 9-12-14 and the page limitation enlarged to 10 pages. (Signed by Judge Victor Marrero on 9/4/2014) (lmb)

From: Richard E. Brodsky

Fax: [phone]

To: Hon. Victor Marrero

Fax: [phone]

THE BRODSKY LA w FIRM,
RICHARD

Page 2 of 3 09/0312014 5:42

PL

E. BRODSKY, ATTORNEY AT LAW
.·

September 3, 2014

By fax to [phone]
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 al,
09-cv-118 (VM) (THK)
SC Cases

Dear Judge Marrero:
I write as the Liaison Counsel for, and on behalf ot: the SC Plaintiffs ("SC Plaintiffs") in
the Standard Chartered Cases.
I wish to bring to the Court's attention differences between two letter endorsements
issued by this Court concerning the same matter.
On July 9, 2014, the undersigned counsel wrote the Court to request approval of an
agreement between the SC PlaintiffS and the SC Defendants with regard to the scheduJing of the
Defendants' intended letter to the Court requesting a pre-motion conference about the filing of a
summary judgment motion. The Jetter recited the parties' agreement to the Defendants' writing
the Court by August 29, 2014 and the Plaintiffs' responding by September 12, 2014 in a letter of
up to ten pages. The Court endorsed the letter as follows: "Request granted. The timing for the
parties' pre-motion conference letter is approved as set forth above." (DE 1285, 7/10/14)
The SC Defendants submitted their letter on August 29, 2014. The Court endorsed the
letter as follows: "SCB litigation plaintiffs are directed to respond by 9-7-14, by letter not to
exceed three (3) pages, to the matter set forth above by SCB defendants." (DE 1314, 9/3/14)
We respectfully request that this Court clarify whether the SC Plaintiffs' letter is due
September 7, 2014 1 and whether the Court will permit that letter to be up to ten pages. We intend
to set forth in summary fashion the reasons that the SC Defendants should not be permitted to
file for summary judgment. We believe that the Court would benefit from the more extended
discussion that will be enabled in a letter of up to ten pages. It~ on the other hand, the Court, by
its July 10, 2014 endorsement, did not intend to convey approval of a letter of up to ten pages, or
1September

7 is a Sunday, so we interpret the Court's endorsement of the SC Defendants' August 29 letter as
establishing a September 8, 2014 deadline.

200 S. BISCAYNE BOULEVARD, STE. 1930 •MIAMI, FLORIDA 33131
WWW.TllEBRULJSKYLAWFIRM.COM
786-220-3328 • RBRODSK Y@THr:BRUDSK Y LAWF!RM.COM

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From: Richard E. Brodsky

Fax: [phone]

To: Hon. Victor Marrero

Fax: +1 i2121 805-6382

Hon. Victor Marrero
September 3, 2014
Page 2

if the Court has changed its mind, we would nevertheless appreciate the opportunity to have until
the time approved in the July 9, 2014 letter (September 12, 2014 ), and request approval of a
letter in excess of three pages but with a lower limit than ten pages, as the Court shall see fit
We appreciate the Court's attention to this request.
Sincerely yours,

cc:

SC Plaintiffs' Counsel
SC Defendants· Counsel