Hasson v. HSBC Bank USA, N.A.
ORDER granting 38 Letter Motion to Stay. This request is GRANTED. The conference scheduled to take place on October 15, 2020 is adjourned sine die. (Signed by Judge Mary Kay Vyskocil on 10/13/2020) (mro)
Case 1:20-cv-01024-MKV Document 39 Filed 10/13/20 Page 1 of 1
DATE FILED: 10/13/2020
September 29, 2020
Raymond A. Garcia
Direct Dial: 212.806.5485
Hon. Mary Kay Vyskocil
Southern District of New York
40 Foley Square
New York, New York 10007
Hasson v. HSBC Bank USA, N.A., U.S.D.C. S.D.N.Y. Case No. 1:20-cv-01024-MKV
Dear Judge Vyskocil:
We represent defendant HSBC Bank USA, N.A. (“HSBC”) in the above-referenced action. We
write, together with plaintiff Gareth Hasson (“Plaintiff”), to jointly request a stay of discovery
pending a ruling on HSBC’s Motion to Compel Arbitration (the “Motion”).
On July 1, 2020, HSBC moved to compel arbitration of Plaintiff’s claims against it. (ECF Nos.
23-25.) The Motion was fully briefed as of August 12, 2020. (ECF No. 32-33.) Notwithstanding
the pendency of the Motion, HSBC voluntarily produced documents and provided inf o rmation
that HSBC would otherwise produce to Plaintiff in arbitration but otherwise has objected to
discovery until its Motion to Compel Arbitration is decided. After extensive conferral, the
parties have reached an impasse on the scope and substance of further discovery, pending the
In the meantime, the parties note that they have in good faith completed their pre-conference
obligations in anticipation of the Settlement Conference before Magistrate Judge Gabriel W.
Gorenstein (ECF No. 31). The Settlement Conference originally was scheduled for September
15, 2020, but on September 14, 2020, Judge Gorenstein adjourned it to September 29, 2020,
and the parties have since worked with Judge Gorenstein to reschedule for October 8, 2020.
In lieu of expending further time, money and resources of both the parties and the Court on
resolving discovery disputes, and engaging in additional efforts that could be mooted in their
entirety if Plaintiff’s claims ultimately are compelled to arbitration, and to allow maximum
effectiveness of the Settlement Conference, the parties jointly request a short discovery stay until
the Court issues its ruling on the fully-briefed Motion to Compel Arbitration. In the event the
Motion is denied, the parties will submit a revised proposed case management plan to conduct
any remaining discovery for the Court’s review and approval.
/s/ Raymond A. Garcia
CC: All Counsel of Record (via ECF)
This request is GRANTED. The conference scheduled to take place
on October 15, 2020 is adjourned sine die.
October 13, 2020
STROOCK & STROOCK & LA
VAN LLP New Y ork Los Angeles Miami Washington, DC
180 Maiden Lane, New Y ork, NY 10038-4982 T. 212.806.5400 F. 212.806.6006 www.stroock.com
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