Stati et al v. Republic of Kazakhstan

Filing 50

MEMO ENDORSED ORDER granting 48 Motion to Vacate GRANTED. ENDORSEMENT: In light of petitioners' representation that they have withdrawn all subpoenas they have issued in this matter, including to the Citibank entities, the Court vacates its order at docket 39. The Clerk of Court is respectfully directed to terminate all pending motions and close this case. SO ORDERED. (Signed by Judge Paul A. Engelmayer on 1/28/2025) (ar).

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l9sEQUORLAW SEQUOR LAW, P.A. 1111 Brickell Ave, Suite 1250 Miami, FL 33131 Tel: 305-372-8282 Fax:305-372-8202 jrome@sequorlaw.com VIA ELECTRONIC COURT FILING January 27, 2025 The Hon. Paul A. Engelmayer United States District Judge Thurgood Marshall U.S. Courthouse 40 Foley Square, Courtroom 1305 New York, NY 10007 Re: Anatolie Stati, et al. v. Republic ofKazakhstan, Case No. 1:19-MC-00382-PAE Agreed Motion to Vacate Opinion and Order [ECF No. 39] Based On Settlement and Related Withdrawal of Subpoena to Citi Dear Judge Engelmayer: Petitioners Anatolie Stati, Gabriel Stati, Ascom Group, S.A., and Terra Raf Trans Traiding Ltd. ("Petitioners" or "Judgment Creditors"), together with Respondent Republic of Kazakhstan ("Respondent" or "Judgment Debtor"), and third-parties Citibank N.A., Citicorp LLC, Citigroup Inc., Citigroup Global Markets Inc., and Citigroup Investments, Inc. (together, "Citi"), hereby file this letter motion pursuantto Fed. R. Civ. P. 60, Local Civil Rules 6.1 and 7. l(e), and Section l(A) of Your Honor's Individual Rules and Practices in Civil Cases, and respectfully state as follows: On July 17, 2024, Your Honor entered an Opinion and Order [ECF No. 39] (the "Order"), which, among other things, granted in part and denied in part Petitioners' motion to compel [ECF No. 27] (the "Motion to Compel") Citi to provide certain information in response to Petitioners' post-judgment subpoenas (the "Subpoenas") within 30 days of the Order, or by August 16, 2024 (the "Response Deadline"). ECF No. 39 at 12-13. The Response Deadline was extended to and through January 31, 2025 in response to prior Agreed Letter Motions seeking to preserve the status quo pending efforts to conclude the settlement anticipated under the framework agreement for the resolution to the long running dispute that inter alia gave rise to the judgment. See ECF Nos. 41, 44 and 46. Petitioners and Respondent confirm that the settlement has been finalized and the parties intend to file a stipulation of dismissal shortly. Petitioners further confirm that the Subpoenas to (i) Citi and (ii) all other subpoenas issued to any other persons in the above-captioned action are withdrawn. Citi is relieved of any obligation to comply with the previously issued subpoenas. 1111 Brickell Avenue, Suite 1250 - Miami, Florida 33131 - Phone 305.372.8282 -www.sequorlaw.com January 27, 2025 Based on the foregoing, the parties respectfully request that Your Honor's prior Order compelling Citi to provide certain information in response to Petitioners' Subpoenas be vacated. Respectfully submitted, By: Isl Fernando J. Menendez Fernando J. Menendez, Esq. Edward H. Davis, Jr. (pro hac vice pending) Joseph Rome, Esq. SEQUORLAW 1111 Brickell Avenue, Suite 1250 Miami, FL 33131 Tel: (305) 372-8282 edavis@sequorlaw.com fmenendez@sequorlaw.com jrome@sequorlaw.com and M. Zachary Bluestone, Esq. BLUESTONE, P.C. 52 Duane St, 7th Floor New York, NY 10007 Tel: (646) 970-7712 mzb@bluestonelaw.com Attorneys for Petitioners Anato/ie Stati, Gabriel Stati, Ascom Group, S.A., and Terra Raf Trans Traiding Ltd. LATHAM & WATKINS LLP DA VIS WRIGHT TREMAINE LLP By: Isl Jamie L. Wine 1271 A venue of the Americas New York, NY 10020 Telephone: (212) 906-1200 Facsimile: (212) 751-4864 Email: jamie.wine@lw.com By: Isl Sharon L. Schneier Sharon L. Schneier 1251 A venue of the Americas, 21st Floor New York, New York 10020 Tel: (212) 489-8230 Fax: (212) 489-8340 sharonschneier@dwt.com Attorneys for Respondent Republic of Kazakhstan Attorneys for Non-Parties Citibank, N.A., Citicorp LLC, Citigroup Inc., Citigroup Global Markets Inc., and Citigroup Investments, Inc. 2 SEQUOR LAW P.A. GRANTED. In light of petitioners' representation that they have withdrawn all subpoenas they have issued in this matter, including to the Citibank entities, the Court vacates its order at docket 39. The Clerk of Comt is respectfully directed to terminate all pending motions and close this case. SO ORDERED. PAULA.ENGELMAYER United States District Judge Dated: January 28, 2025 New York, New York I

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