Invictus Global Management, LLC v. Apollo Global Management, Inc. et al
Filing
18
ORDER granting 17 Letter Motion for Extension of Time to File. SO ORDERED. (Signed by Judge Andrew L. Carter, Jr on 6/22/2022) (ate)
Case 1:22-mc-00130-ALC Document 18 Filed 06/22/22 Page 1 of 2
(212) 373-3166
(212) 492-0166
aehrlich@paulweiss.com
6/22/2022
June 22, 2022
BY ECF & E-mail
Hon. Andrew L. Carter, Jr.
United States District Court
Southern District of New York
Thurgood Marshall United States Courthouse
40 Foley Square, Room 435
New York, NY 10007
Re:
In re Invictus Global Management, LLC, Case No. 22-mc-00130 (S.D.N.Y.)
Second Joint Request to Extend Discovery Deadlines
Dear Judge Carter:
Pursuant to this Court’s Individual Rule 1(D), we are writing on behalf of
Respondents Apollo Global Management, Inc., and Marc Rowan and, with its counsel’s
consent, Petitioner Invictus Global Management, LLC, to ask the Court for a second
extension of time as set out below.
Petitioner filed this 28 U.S.C. § 1782 proceeding on May 6, 2022 (ECF
No. 1). On May 9, before this matter was assigned to Your Honor, Judge Preska entered
an ex parte order (ECF No. 11) authorizing discovery under that provision, directing
Petitioner to serve that order on Respondents, and directing Respondents to comply with
the subpoenas accompanying Petitioner’s petition by June 8. Petitioner effected service
on Apollo on May 13, and on Mr. Rowan (through counsel) on May 31.
Case 1:22-mc-00130-ALC Document 18 Filed 06/22/22 Page 2 of 2
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On May 31, 2022, the parties met and conferred, and agreed to extend the
time for Respondents to make a motion to quash Petitioner’s subpoenas, if any, by June
24. Respondents filed their first joint letter requesting an extension for time to file a
motion to quash Petitioner’s subpoenas on June 3, 2022. (ECF No. 13.)
On June 6, 2022, Respondents filed an amended joint letter to clarify that
the request to extend the deadline of any motion to quash, should one be necessary, was
intended to apply to any party’s motion to quash that has standing to so file, and not just
Respondents’ motion. (ECF No. 15.) The parties requested the Court endorse the
following schedule: (i) any party shall have until June 24, 2022 to file a motion to quash;
(ii) Petitioner shall have until July 15, 2022 to file its opposition; and (iii) any moving
party shall have until July 29, 2022 to file a reply submission.
On June 17, 2022, the parties met and conferred to negotiate the
parameters of Respondents’ response to Petitioner’s subpoenas, and agreed, in light of
their ongoing efforts to reach agreement on the scope of discovery in this matter, to
another extension of time for any party that has standing to file a motion to quash to file
one. The parties thus request that the Court endorse the following amended schedule: (i)
any party shall have until July 22, 2022 to file a motion to quash; (ii) Petitioner shall have
until August 12, 2022 to file its opposition; and (iii) any moving party shall have until
August 26, 2022 to file a reply submission. The parties have agreed to hold any
deposition requests in abeyance pending their document discovery negotiations, without
prejudice to the right of Petitioner to re-notice such depositions.
This letter constitutes the parties’ second joint request for an extension to
discovery deadlines. This proposed extension will not affect any other dates in this
matter.
We thank the Court for its consideration of this matter.
Respectfully submitted,
/s/ Andrew J. Ehrlich .
Andrew J. Ehrlich
cc: All Counsel of Record (via ECF)
Dated: 6/22/2022
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