Republic of Turkey v. Christie's Inc. et al

Filing 301

ORDER granting 300 LETTER MOTION for Extension of Time to File Pre-Trial Submissions addressed to Judge Alison J. Nathan. Document filed by Republic of Turkey. So ordered. Plaintiff's request is hereby granted. The Court adopts Plaintiff's proposed revised schedule for the filing of pretrial materials. SO ORDERED. (Signed by Judge Alison J. Nathan on 3/30/2020) (rjm)

Case 1:17-cv-03086-AJN-SDA Document 300 Filed 03/24/20 Page 1 of 4
3/30/20

Lawrence M. Kaye
Partner
Phone:
Fax:

212.592.1410
212.545.3331

[e-mail]

March 24, 2020
VIA ECF
The Honorable Alison J. Nathan
United States District Judge
United States District Court for the Southern District of New York
Thurgood Marshall U.S. Courthouse
40 Foley Square
New York, New York 10007
Re:

SO ORDERED

3/30/20

Alison J. Nathan, U.S.D.J.

Republic of Turkey v. Christie’s Inc. and Michael Steinhardt, 17 Civ. 3086 (AJN)

Your Honor:
We are the attorneys for Plaintiff, Republic of Turkey (“Plaintiff” or “Republic”). We appreciate
the Court’s prompt ruling on the parties’ joint request last week for extensions of the pre-trial
submission deadlines and the adjournment sine die of the trial in this case. (Dkt #297). We are
writing your Honor again, however, because much has changed since last week when we made the
application for an adjournment and even since last Friday when your Honor granted the
application, necessitating this further application for an extension of the pretrial deadlines.
On March 22, 2020, Herrick, Feinstein LLP, the attorneys for Plaintiff, in response to Governor
Cuomo’s March 20, 2020 Executive Order (No. 202.8), closed its office, except to permit access
to two staff personnel in the mailroom and IT staff only as needed. Partners, associates and other
employees at the firm are no longer permitted access to the office. In addition, the transition from
an office environment to everyone working remotely has caused connectivity problems and, in at
least three cases, serious technical failures and delays. Our firm’s IT staff is simply overwhelmed.
Accordingly, our ability to meet the so-ordered filing deadlines has been compromised.
On top of that, because of New York City’s recent and alarming developments concerning the
spread of COVID-19, two of Plaintiff’s attorneys and their families have temporarily relocated
outside of the City which adds to the complications.
In light of the foregoing intervening circumstances which are causing and may well continue to
cause delays, we respectfully request a further adjournment of the April 3, 2020 deadlines for the
submission of pretrial papers until April 24, 2020 (and similar extensions for the few later
submissions). Our new proposed schedule is attached. We have considered in making this request
that Passover and Easter will occur during this period. Most importantly, we believe that there
will be no prejudice to any party because the trial is currently adjourned sine die. And the parties
will still be in a position to suggest a new trial date on April 27, 2020, as your Honor directed in
HERRICK, FEINSTEIN LLP

●

Two Park Avenue

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New York, NY 10016

●

Phone: [phone]

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Fax: [phone]

Case 1:17-cv-03086-AJN-SDA Document 300 Filed 03/24/20 Page 2 of 4

The Honorable Alison J. Nathan
March 24, 2020
Page 2
last week’s order. Defendants’ counsel has advised us that Defendants will take no position on
Plaintiff’s request for a 3-week extension.

Respectfully submitted,

/s/ Lawrence M. Kaye
Lawrence M. Kaye
HERRICK, FEINSTEIN LLP
2 Park Avenue
New York, NY 10016
[e-mail]
212-592-1410 Telephone
212-592-1500 Facsimile
Attorneys for Plaintiff
Republic of Turkey

Enclosure

cc: All Counsel of Record (via ECF)

Plaintiff's request is hereby granted. The Court
adopts Plaintiff's proposed revised schedule for the
filing of pretrial materials.
SO ORDERED.

Case 1:17-cv-03086-AJN-SDA Document 300 Filed 03/24/20 Page 3 of 4

Current Date
Joint Pretrial Report (Rule 6.A):
• Statement regarding subject matter jurisdiction
• Summary of claims and defenses to be tried
• Statement as to number of trial days needed
• Any stipulations or agreed statements of fact or law
to which all parties consent
• List of witnesses who will testify at trial and a brief
summary of the substance of each witness’
testimony
• Designations of deposition testimony to be presented
to the court and any counter-designations and
objections to admissibility by any other party
• Exhibit lists, including any objections to
admissibility by the other party
• A statement of the damages claimed and any other
relief sought

April 3, 2020

Proposed New
Date
April 24, 2020

Motions in limine (Rule 6.B.)

April 3, 2020

April 24, 2020

Pretrial Memorandum of Law (Rule 6.C.)
(optional)

April 3, 2020

April 24, 2020

Trial Exhibits (Rule 6.E.)

April 3, 2020

April 24, 2020

Proposed Findings of Fact and Conclusions of Law (Rule
6.F.i.)

April 3, 2020

April 24, 2020

Deposition Excerpts
(Rule 6.F.ii.)

April 3, 2020

April 24, 2020

Direct Testimonies of Trial Witnesses (Rule 6.F.iii.)

April 3, 2020

April 24, 2020

Courtesy Copies (Rule 6.G)

List of Affiants to Cross-Examine (Rule 6.F.iii.)

As soon as
practically
possible after
filing
April 8, 2020

As soon as
practically
possible after
filing
April 29, 2020

Oppositions to motions in limine (Rule 6.B.)

April 22, 2020

May 8, 2020

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Case 1:17-cv-03086-AJN-SDA Document 300 Filed 03/24/20 Page 4 of 4

Replies to motions in limine (Rule 6.B.)

May 1, 2020

May 18, 2020

Final pretrial conference

TBD

TBD

Trial Date

TBD

TBD

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