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 ENDORSEMENT: In light of petitioners' representation that they have withdrawn all subpoenas they have issued in this matter, including to the Citibank entities, the Court vacates its order at docket 39.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).
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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