Neuhauser v. Bolivarian Republic of Venezuela

Filing 64

ORDER granting 63 Letter Motion for Extension of Time to File. GRANTED. SO ORDERED. (Signed by Judge Analisa Torres on 3/11/2025) (vfr)

Davis+Gilbert LLP
1675 Broadway
New York, NY 10019
212 468 4800
dglaw.com

3/11/2025

Joshua H. Epstein
d 212 468 4869
[e-mail]

March 10, 2025
Via ECF and Email ([e-mail])
The Hon. Analisa Torres
United States District Court
Southern District of New York
Daniel Patrick Moynihan United States Courthouse
500 Pearl St.
New York, NY 10007-1312
Neuhauser v. Bolivarian Republic of Venezuela/Case No. 1:20-CV-10342 (AT)
Dear Judge Torres:
We represent plaintiff Alexander Neuhauser (“Plaintiff”) in the above-referenced action.
Pursuant to section I(C) of Your Honor’s Individual Practices in Civil Cases, we submit this lettermotion to request an extension of time until June 12, 2025 to file a revised motion for default
judgment.
On July 3, 2023, this Court filed a certain order denying Plaintiff’s motion for default
judgment without prejudice to renewal, and providing Plaintiff until August 3, 2023 to file a revised
motion (see Dkt. No. 43). Previously, on July 20, 2023, this Court granted Plaintiff’s first letter
motion for an extension of time until September 8, 2023 (see Dkt. No. 45), on September 6, 2023,
this Court granted Plaintiff’s second letter motion for an extension of time until October 9, 2023
(see Dkt. No. 47), on October 6, 2023, this Court granted Plaintiff’s third letter motion for an
extension of time until December 6, 2023 (see Dkt. No. 49), on December 5, 2023, this Court
granted Plaintiff’s fourth letter motion for an extension of time until March 6, 2024 (see Dkt. No.
51), on March 6, 2024, this Court granted Plaintiff’s fifth letter motion for an extension of time until
June 6, 2024 (see Dkt. No. 53), on June 5, 2024, this Court granted Plaintiff’s sixth letter motion
for an extension of time until September 11, 2024 (see Dkt. No. 57), on September 10, 2024, this
Court granted Plaintiff’s seventh letter motion for an extension of time until December 11, 2024
(see Dkt. No. 59), on December 10, 2024, this Court granted Plaintiff’s eighth letter motion for an
extension of time until March 12, 2025 (see Dkt. No. 62).
We are requesting this ninth extension of time because on June 3, 2024, Vinson & Elkins
appeared as counsel on behalf of the Bolivarian Republic of Venezuela (“Defendant”) (see Dkt.
Nos. 54 and 55). Following this appearance by Defendant’s counsel, the parties’ are continuing
discussions regarding the status of this action and how to best resolve the same. Additionally,

District Judge Analisa Torres
March 10, 2025
Page 2

Plaintiff is elderly and unfortunately faces significant and continuing health issues. We have been
diligently following up with Plaintiff, but communications have been delayed. To that end, we
respectfully request additional time to facilitate these discussions between the parties.
This is Plaintiff’s ninth request for an extension of time to file a revised motion for default
judgment. We apologize to this Court for Plaintiff’s delay in filing the revised motion and greatly
appreciate the Court’s consideration. Please let me know if there is any additional information
that Plaintiff can provide to the Court related to this request.
Respectfully,
/s/ Joshua H. Epstein
Joshua H. Epstein
cc:

Dora Georgescu, Esq., Vinson & Elkins (by ECF)
Andreina Escobar, Esq., Vinson & Elkins (by ECF)

GRANTED.
SO ORDERED.
Dated: March 11, 2025
New York, New York