Nypl v. JP Morgan Chase & Co. et al

Filing 622

ORDER granting 621 Letter Motion for Extension of Time to File. Application GRANTED. The application is untimely but is nevertheless granted. The parties shall file the joint status letter, pursuant to the order at Dkt. No. 574, by August 21, 2020. (Signed by Judge Lorna G. Schofield on 8/10/2020) (cf)

Case 1:15-cv-09300-LGS Document 622 Filed 08/11/20 Page 1 of 2

Application GRANTED. The application is untimely but is nevertheless granted. The parties shall file the
joint status letter, pursuant to the order at Dkt. No. 574, by August 21, 2020.
Dated: August 10, 2020
New York, New York

Re:

Nypl, et al. v. JPMorgan Chase & Co., et al.
S.D.N.Y. Case No. 1:15-CV-09300 (LGS)

Dear Judge Schofield:
This firm is counsel to the Citi defendants in the above-referenced action. I write with
the consent of all parties referenced below to request an adjournment of the August 7, 2020
deadline for a joint letter about the status of certain discovery issues. No extensions of this
deadline have previously been requested.
Your Honor’s Order of June 4, 2020 (ECF No. 547) permitted plaintiffs to serve
interrogatories on defendants Barclays, Citi, JPMorgan, RBS, and UBS “to address the threshold
question of what communications, if any, each Defendant had with the Government relating to
the plea agreements” referenced in the stipulation the Court approved on March 18, 2018 (ECF
No. 425). Pursuant to the June 4 Order, plaintiffs served a Fourth Set of Interrogatories on each
of these defendants on June 11. On July 1, the parties reported to the Court concerning the terms
of an agreement for defendants to serve responses to these interrogatories by July 27. (ECF No.
573.) On July 2, the Court entered an endorsement order approving that agreement, and asked
the parties to file a joint status letter by August 7 (today) to “(1) apprise the Court of the status of
the interrogatory responses, any supplemental responses and any related disputes; (2) inform the
Court of whether Plaintiffs intend to seek depositions based on the interrogatory responses, the
proposed dates for any such depositions and any related disputes; and (3) propose appropriate
amendments to Sections II and IV of the Third Amended Civil Case Management Plan and
Scheduling Order (Dkt. No. 548).”1 (ECF No. 574.)

1

Section IV of the Third Amended Civil Case Management Plan has already been amended by
this Court. See ECF No. 615, Fourth Amended Civil Case Management Plan and Scheduling
Order, at 1-2 (July 31, 2020).

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Page 2
Defendants served responses to the above-referenced interrogatories on July 27.
Plaintiffs have indicated they would benefit from additional time to consider next steps. To
accommodate this request, to allow sufficient time for the parties to meet and confer to try to
narrow any potential disputes, and in light of vacation schedules, the parties respectfully propose
to proceed as follows: Plaintiffs will notify defendants by August 14 whether they are seeking
supplementation of the July 27 interrogatory responses and/or depositions, and what
amendments, if any, they are seeking to Sections II and IV of the scheduling order. Defendants
reserve all rights with respect to any requests plaintiffs may make. The parties will then meet
and confer on these issues during the week of August 17, and will file the joint status letter
previously requested by the Court by 6 p.m. ET on August 21.
Respectfully submitted,
s/ Andrew A. Ruffino
cc:

All Counsel (by ECF)