Invictus Global Management, LLC v. Apollo Global Management, Inc. et al

Filing 20

ORDER granting 13 Letter Motion for Extension of Time to File ; granting 19 Letter Motion for Extension of Time. SO ORDERED. (Signed by Judge Andrew L. Carter, Jr on 7/21/2022) (ate)

Case 1:22-mc-00130-ALC Document 20 Filed 07/21/22 Page 1 of 2

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7/21/2022
July 20, 2022

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.)
Third 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 an 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 20 Filed 07/21/22 Page 2 of 2
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On May 31, 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. (ECF No. 13.) The parties thereafter
requested another extension of time while their discovery negotiations continued (ECF
No. 17), and the Court endorsed the parties’ proposed amended schedule, extending
Respondents’ deadline until July 22. (ECF No. 18.)
The parties’ discovery negotiations are still ongoing as of this time. As a
result, the parties believe that another extension of Respondents’ deadline is appropriate,
and would further facilitate the parties’ efforts. To that end, the parties now request that
the Court endorse the following amended schedule: (i) any party shall have until August
12, 2022 to file a motion to quash, if any; (ii) Petitioner shall have until August 26, 2022
to file its opposition to any such motion; and (iii) any moving party shall have until
September 9, 2022 to file a reply submission, if any. The parties also intend for the time
being to defer any depositions as their negotiations continue.
This letter constitutes the parties’ third joint request for an extension to
discovery deadlines. This new requested 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: 7/21/2022

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