US Airways, Inc., for American Airlines, Inc. as Successor and Real Party in Interest v. Sabre Holdings Corporation et al

Filing 1064

ORDER granting #1063 Letter Motion for Extension of Time to File. Application GRANTED. The deadline to file any motions to seal is extended to December 20, 2021. (Signed by Judge Lorna G. Schofield on 11/19/2021) (vfr)

O’Melveny & Myers LLP
Times Square Tower
7 Times Square
New York, NY 10036-6537

November 18, 2021

T: [phone]
F: [phone]
omm.com

Application GRANTED. The deadline to file any motions to seal is
extended to December 20, 2021.
Dated: November 19, 2021
New York, New York

VIA ECF

Andrew J. Frackman
D: [phone]
[e-mail]

Hon. Lorna G. Schofield
United States District Court
Thurgood Marshall United States Courthouse
40 Foley Square
New York, NY 10007
Re:

US Airways, Inc., for American Airlines, Inc. as Successor and Real Party in
Interest v. Sabre Holdings Corp., et al., No. 1:11-cv-02725-LGS
Joint Letter Motion to Extend Time to File Sealing Motions

Dear Judge Schofield:
We write on behalf of the parties in the above-captioned case, and pursuant to Your
Honor’s Individual Rule I.B.2, to jointly request an extension of time to file sealing motions for
documents submitted in support of and in opposition to Sabre’s Motion for Summary Judgment
(Dkt No. 1038) and Sabre’s Daubert Motion to Exclude Certain Testimony of Dr. Rosa AbrantesMetz (Dkt. No. 1042). The parties filed the relevant materials conditionally under seal and the
current deadline to file any sealing motions is November 29, 2021 (Dkt. No. 1033). The parties
are meeting and conferring with each other in an attempt to resolve any disputes prior to filing
the motions to seal, and must coordinate with at least nine third parties that marked as
confidential material used in connection with the summary judgment and Daubert motions.
Given the high volume of papers that the parties (and third parties) must review1—and also in
light of the intervening Thanksgiving holiday, which complicates the necessary coordination,
including with third parties—the parties seek an extension until December 20, 2021 for their
motions to seal. This is the first request for an extension of time.
Respectfully submitted,

Andrew J. Frackman
of O’MELVENY & MYERS LLP
for US Airways, Inc. for American Airlines, Inc. as
Successor and Real Party in Interest
cc:

Counsel for Sabre (via ECF)

1

Between the summary judgment and Daubert motions, the parties must review more than 1,000 pages
of documents.

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