Lelchook et al v. Lebanese Canadian Bank, SAL et al

Filing 82

ORDER granting 81 Letter Motion for Extension of Time to File. APPLICATION GRANTED. (Signed by Magistrate Judge Katharine H. Parker on 8/1/2022) (vfr)

Case 1:08-cv-07253-GBD-KHP Document 175 Filed 07/29/22 Page 1 of 1

July 29, 2022
Hon. Katharine H. Parker
United States Magistrate Judge
United States District Court for the Southern District of New York
Daniel Patrick Moynihan United States Courthouse
500 Pearl Street
New York, New York 10007
Re:

08/01/2022

Kaplan, et al. v. Lebanese Canadian Bank, 08-cv-7253-GBD-KHP
Lelchook, et al. v. Lebanese Canadian Bank, et al. 18-cv-12401-GBD-KHP

Dear Judge Parker:
We represent Plaintiffs in the above-referenced actions. On June 30, 2022, Your Honor
entered scheduling orders in both cases, which directed that: “[t]he parties shall file a joint
proposed ESI plan and protective order by July 29, 2022 for the Court’s review and adoption.”
(Kaplan, DE 171, p. 2; Lelchook, DE 73, p. 2). We write with the consent of Defendants to request
that the parties’ deadline to file the joint proposed ESI Plan and Protective Order be extended until
August 12, 2022.
Good cause exists for the enlargement sought. The parties are attempting to resolve their
disagreements regarding the proposed ESI plan and protective order but significant gaps remain.
The parties are nonetheless hopeful that further discussions will resolve or at least narrow their
disagreements, and thereby obviate or limit the need for the Court to hear and resolve the dispute.
The enlargement is thus likely to preserve the resources of both the Court and the parties. The
enlargement will not delay these actions because no discovery productions are scheduled in the
next couple of weeks. We also note that pursuant to the scheduling orders (id.), the parties will be
submitting a joint status letter on August 12, 2022. Thus, the enlargement requested would make
the proposed ESI plan and protective order due at the same time as the joint status letter.
This request is filed with the consent of Defendants’ counsel, Mitchell R. Berger, Esq.
We thank the Court for its consideration.

Respectfully,
8/01/2022
Cc: All counsel of record by ECF

Robert J. Tolchin