Anwar et al v. Fairfield Greenwich Limited et al

Filing 1368

ENDORSED LETTER addressed to Judge Victor Marrero from David A. Barrett dated 4/21/2015 re: We write on behalf of all parties in the above-referenced action in response to the Court's request at the conference on April 14, 2015 to submit a proposed trial and mediation schedule. 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 parties., ( Motions due by 11/2/2015.) (Signed by Judge Victor Marrero on 4/21/2015) (lmb)

04/21/2015 15:45 FAX

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575 LEXINGTON AVENUE• 7TH FLOOR• NEW YORK, NY 10022 •PH. 212.446 2300' FAX [phone]

April 21, 2015

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Re:

Anwar, et al. v. Fairfield Greenwich Limited, et al.
Master File No. 09-CV -00118 (VM) (FM)

Dear Judge Marrero:
We write on behalf of all parties in the above-referenced action in response to the Court's
request at the conference on April 14, 2015 to submit a proposed trial and mediation schedule.
The parties have met and conferred in good faith and agreed upon the following schedule:
•

•

September 1, 2015: Parties to file any summary judgment motions by this date, or a
party may defer, without prejudice, the filing of its summary judgment motion (or
Rule 50 motion) until the close of the opposing parties' case-in-chief. Under either
procedure, no response to any such motions shall be filed pending further instruction
of the Court, which may not rule on such motions prior to trial. Defendants object to
the foregoing procedure, and reserve the right to seek reconsideration.

•

September 1, 2015: Plaintiffs provide defendants with draft pre-trial submissions,
including designations of depositions. 1

•

September 15, 2015: Parties to file any Daubert motions, with responses due 30 days
thereafter and replies 15 days thereafter.

•

1

June 18, 2015: Parties to participate in mediation by this date; the parties have
scheduled a mediation on June 17 before Hon. Layn Phillips.

October 1, 2015: Defendants provide plaintiffs with draft pre-trial submissions,
including designations of depositions.

The Court's standing Trial Procedures shall govern the parties' pre-trial submissions.

WWW.SSFLLP.COM

04/21/2015 15:46 FAX

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212 446 2350

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The Honorable Victor Marrero
April 21, 2015
Page2

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November 2, 2015: Parties to file final pre-trial joint submissions in accordance with
Court's standing trial procedures, together with objections to designated deposition
testimony. Parties to file motions in limine, with responses due 14 days thereafter and
replies 7 days thereafter.

•

December 1, 2015: Case ready for Final Pre-Trial Conference.

•

January 4, 2015: Jury trial of6 weeks commences. Plaintiffs believe the trial can be
concluded in 4-6 weeks. Defendants believe the trial will require 8-12 weeks.

The parties are available to discuss these matters at the Court's convenience or otherwise
to provide further information.

AJ;pµr
Respectfully yours,

David A. Barrett
cc:

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Anwar counse1 ~ oy e-mauJ

The ~!erk_ of Court is directed to enter into the public record
. ofth1s action the letter above submitted to the Court by

./#k~SOORDERED.

bATE

003/003