Mayaguez S.A. v. Citigroup Inc. et al

Filing 212

ORDER granting 209 Letter Motion for Extension of Time to File. The Application is granted. SO ORDERED. (Signed by Judge Paul G. Gardephe on 5/6/2020) (ks)

Case 1:16-cv-06788-PGG-JLC Document 209 Filed 05/05/21 Page 1 of 1

May 5, 2021
VIA ECF
The Honorable Paul G. Gardephe
United States District Court
Southern District of New York
40 Foley Square
New York, NY 10007
Re:

May 6, 2021

Mayagüez SA. v. Citigroup, Inc., et al., Case No. 16 Civ. 06788 (PGG) (JLC)

Dear Judge Gardephe:
We write on behalf of all parties to this action. In accordance with paragraph I(D) of Your
Honor’s Individual Rules of Practice (the “Rules of Practice”), Defendants request a 14-day
extension (to which Plaintiff consents) for the parties’ time to file any objections, and responses
to any such objections, to the Report and Recommendation of Magistrate Judge James L. Cott
(the “R&R”) with respect to the parties’ motions for summary judgment.
The R&R, transmitted to the parties on April 30, 2021, is over 70 pages and addresses motions
for summary judgment and related motions filed by both sides under both Colombian and New
York law with respect to Plaintiff’s 11-count complaint. Under the applicable rules, the parties’
objections to the R&R would be due within 14 days of transmittal, i.e., May 14, and responses to
such objections would be due 14 days after service of such objections. See FRCP Rule 72(b).
The following brief extension is requested to permit the parties to assess and address any
potential objections and responses thereto: the parties shall file any objections to the R&R on or
before May 28, 2021; and the parties shall file any responses to any such objections on or before
June 25, 2021.
No extension of time has been sought previously for these deadlines.
Respectfully submitted,
/s/ Gabriel F. Soledad
Juan P. Morillo
Gabriel F. Soledad
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
1300 I Street NW, Suite 900
Washington, D.C. 20005
Tel. [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiff

/s/ Agnès Dunogué
Adam S. Hakki
Agnès Dunogué
SHEARMAN & STERLING LLP
599 Lexington Avenue
New York, NY 10022
Tel. [phone]
Tel. [phone]
[e-mail]
[e-mail]
Attorneys for Defendants