American Lecithin Company et al v. Rebmann

Filing 328

ORDER granting 325 Letter Motion for Discovery. APPLICATION GRANTED. The parties shall produce the requested documents by May 1, 2023. I will issue a separate order addressing the proposed remote deposition protocol. SO ORDERED.. (Signed by Judge Vernon S. Broderick on 4/17/2023) (kv)

Case 1:12-cv-00929-VSB-JW Document 328 Filed 04/17/23 Page 1 of 1

Gregory F. Hauser | Partner
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April 14, 2023
By ECF:
Hon. Vernon S. Broderick
United States District Judge
United States Courthouse
40 Foley Square
New York, NY 10007
Re:

04/17/2023

The parties shall produce the requested
documents by May 1, 2023. I will issue a
separate order addressing the proposed
remote deposition protocol.

Am. Lecithin Co. et al. v. Rebmann, 12-CV-929 (VSB)

Your Honor:
This firm represents the Plaintiffs and the Third-Party Defendant in the above-referenced
case. This letter is in regard to the Court’s January 31, 2023 order that “[t]he deadline for the
parties to produce documents shall be April 17, 2023” (Dkt. 317). The parties have met and
conferred regarding their anticipated document productions and are in the process of completing
thorough searches. Defendant’s counsel joins me in respectfully requesting a two-week extension
of the April 17 deadline to allow adequate time to complete production. We greatly appreciate the
Court’s consideration of our request.
Additionally, in connection with the Court’s orders of March 22, 2023 and April 5, 2023
(Dkts. 322 & 324), the parties respectfully submit their proposed remote-deposition protocol as
Exhibit A. The parties have met and conferred concerning the protocol and are in agreement
regarding all provisions except for a portion of the second paragraph (concerning permissible
data-privacy objections). The parties have set forth their respective positions on the disputed
provision on pages two and three of the proposed protocol.
Thank you for your attention to this matter.
Respectfully yours,

Gregory F. Hauser
Cc: Joshua E. Abraham, Esq. (by ECF)