Bulgari v. Bulgari

Filing 58

ORDER denying as moot 56 Letter Motion to Stay re: 56 LETTER MOTION to Stay Deposition Scheduled for 11/18/22, addressed to Magistrate Judge Robert W. Lehrburger from Michael M. Rosensaft dated 11/17/22. As per the telephone conference held on November 17, 2022, the application for protective order is denied as moot. SO ORDERED.. (Signed by Magistrate Judge Robert W. Lehrburger on 11/17/2022) (kv)

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Case 1:22-cv-05072-LGS-RWL Document 58 Filed 11/17/22 Page 1 of 2 50 Rockefeller Plaza New York, NY 10020-1605 +1.212.940.8800 tel katten.com.. MICHAEL M. ROSENSAFT michael.rosensaft@katten.com +1.212.940.6631 direct +1.212.940.8776 fax November 17, 2022 VIA ECF Hon. Robert W. Lehrburger United States District Court Southern District of New York 500 Pearl Street, Rm. 1960 New York, NY 10007 Re: 11/17/2022 Matter of Bulgari v. Bulgari, No. 1:22-cv-05072-LGS-RWL Dear Judge Lehrburger: We are counsel for defendant, Veronica Bulgari, in the action referenced above. I am sorry to impose on Your Honor with this letter but the parties have reached an impasse on a matter that, I regret to say, requires the Court’s attention today if that is at all possible. On Tuesday of this week at 4:04 PM, the plaintiff sent us, by email, a notice of deposition of a third party witness. The notice set the deposition for tomorrow, Friday, at 10 AM, in Fort Lauderdale, Florida. Plaintiff had made no effort to discuss the date or place of the deposition with us in advance. We simply had no warning that we would be given about 66 hours notice of a deposition set to occur 1500 miles away. We have asked plaintiff to delay the examination to any other day but plaintiff has refused, insisting that because the witness was hard to serve, the deposition could not be rescheduled. But that has no bearing on why plaintiff set the deposition for tomorrow when counsel are set to appear before Your Honor at the precise time that the deposition is apparently going to occur. We have no objection to the deposition of the witness in question, over whom we have no control and do not know how to reach. But we request that the Court issue a protective order staying the deposition as currently scheduled for tomorrow and requiring plaintiff to work cooperatively to reschedule it for another, mutually agreeable date and time. KATTEN MUCHIN ROSENMAN LLP CENTURY CITY NEW YORK CHARLOTTE ORANGE COUNTY CHICAGO DALLAS SHANGHAI LOS ANGELES WASHINGTON, DC A limited liability partnership including professional corporations LONDON: KATTEN MUCHIN ROSENMAN UK LLP Case 1:22-cv-05072-LGS-RWL Document 58 Filed 11/17/22 Page 2 of 2 November 17, 2022 Page 2 Respectfully Submitted, /s/ Michael M. Rosensaft Michael M. Rosensaft Jake A. Nussbaum KATTEN MUCHIN ROSENMAN LLP 50 Rockefeller Plaza New York, NY 10020 T: 212-940-8800 michael.rosensaft@katten.com jake.nussbaum@katten.com /s/ Mitchell A. Karlan Mitchell A. Karlan Jennifer K. Bracht GIBSON, DUNN & CRUTCHER LLP 200 Park Avenue New York, NY 10166 T: 212-351-3827 mkarlan@gibsondunn.com Attorneys for Defendant Veronica Bulgari As per the telephone conference held on November 17, 2022, the application for protective order is denied as moot. 11/17/2022

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