Matthew Stein et al v. Skatteforvaltningen

Filing 97

ORDER: granting in part 96 Letter Motion for Extension of Time to File. Application granted in part. Stein, Lhote, and McGee are directed to propound their proposed discovery requests to SKAT by Sunday, March 17, 2024 at 12:00 p.m. The deadline to submit the requests to the Court is Monday, March 18, 2024 at 12:00 p.m. Submissions must be made by that deadline both electronically via ECF and in hard copy to the Court. The moving party shall submit two single-sided copies. Any objections to these requests must be submitted to the Court by Tuesday, March 19, 2024 at 12:00 p.m. SO ORDERED. (Signed by Judge Naomi Reice Buchwald on 3/14/2024) (ama)

Case 1:23-cv-02508-NRB Document 96 Filed 03/14/24 Page 1 of 2

Daniel W. Levy
Direct Dial: [phone]
E-mail: [e-mail]

1301 Avenue of the Americas
32nd Floor
New York, NY 10019

Telephone: [phone]
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March 14, 2024
By ECF
The Honorable Naomi Reice Buchwald
United States District Judge
Southern District of New York
500 Pearl Street, Room 2270
New York, New York 10007
Re:

Stein and Lhote v. Skatteforvaltningen
23 Civ. 2508 (NRB)

Dear Judge Buchwald:
We write on behalf of Plaintiffs-Counterclaim Defendants Matthew Stein and
Jerome Lhote and jointly with counsel for Counterclaim Defendant Luke McGee.
We respectfully request that the Court permit Stein, Lhote, and McGee until
Tuesday, March 19, 2024, to submit to the Court a request under the Hague
Convention to obtain overseas evidence.
The parties had proposed via Stipulation and Proposed Order (ECF No. 91)
that the last day to seek to have the Court authorize a Hague Convention request be
March 13, 2024. The Court has not yet entered the Proposed Order.
We seek two additional business days beyond the date agreed to by the parties
in order to properly determine the nature and scope of the Hague Convention
request to be sought from the Court. Preparing this material has been more timeconsuming than anticipated and has involved, among other things, coordination with
counsel in Denmark.
We sought the consent of Defendant-Counterclaim Plaintiff
Skatteforvaltningen to extend the time set out in the parties’ Stipulation from
Wednesday, March 13, through Tuesday, March 19.

McKool Smith

A Professional Corporation • Attorneys
Austin | Dallas | Houston | Los Angeles | Marshall | New York | Washington, DC

4876-5257-2333

Case 1:23-cv-02508-NRB Document 96 Filed 03/14/24 Page 2 of 2

The Honorable Naomi Reice Buchwald
March 14, 2024
Page 2
SKAT agreed to extend the date from Wednesday, March 13, until Friday,
March 15, but was unwilling to consent to extending the date until Tuesday, March
19. They were unwilling to provide any explanation of why extending the deadline
agreed to by the parties by two business days was agreeable, but that extending the
deadline by four business days was not.
Stein, Lhote, and McGee make this request in good faith and submit that
SKAT would not be prejudiced by this extremely short extension of the deadline
agreed to by the parties.
Counsel for Stein, Lhote, and McGee are available to discuss their request at
the Court’s convenience.
Respectfully submitted,
/s/
Daniel W. Levy
Application granted in part. Stein,
Lhote, and McGee are directed to
propound their proposed discovery
requests to SKAT by Sunday, March
17, 2024 at 12:00 p.m. The deadline
to submit the requests to the Court
is Monday, March 18, 2024 at 12:00
p.m. Submissions must be made by
that deadline both electronically
via ECF and in hard copy to the
Court. The moving party shall
submit two single-sided copies.
Any objections to these requests
must be submitted to the Court by
Tuesday, March 19, 2024 at 12:00
p.m.

Dated: March 14, 2024
New York, NY
4876-5257-2333