Everlake Life Insurance Company v. Freedom U.S. Acquisition Corporation et al

Filing 13

ORDER granting #12 Letter Motion to Adjourn Conference. Application granted. The parties shall file a joint status letter no later than May 17, 2024. The parties' deadline to file a case management plan is adjourned. The initial status conference originally scheduled for May 24, 2024 is also adjourned. Following a decision on the Dispositive Motions, the Court will schedule a deadline for the joint submission of a case management plan and a date for the status conference, should they be necessary. SO ORDERED. (Signed by Judge Ronnie Abrams on 5/10/2024) (vfr)

425 Lexington Ave., 14th Floor
New York, New York 10017
Tel: [phone]
Fax: [phone]
www.hsgllp.com
Vincent Levy
[phone]
[e-mail]
May 10, 2024
BY ECF
The Honorable Ronnie Abrams
United States District Judge
Thurgood Marshall United States Courthouse
40 Foley Square
New York, NY 10017
Re: Everlake Life Ins. Company v. Freedom U.S. Acquisition Corp. et al., No. 24-cv-3264 (RA)
Dear Judge Abrams:
I write respectfully on behalf of all parties to request that the Court defer certain initial
deadlines until after the Dispositive Motions, as defined below, are resolved and that the initial
status conference, currently scheduled for May 24, 2024, be rescheduled for a date in June.1
Plaintiff filed the above-referenced action in New York state court on March 22, 2024. DE
1-1. Defendants removed the case to federal court on April 29, 2024. DE 1. On April 30, the
Court issued an order setting forth three initial deadlines (DE 6):
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


May 17, 2024: Parties jointly submit a status letter
May 17, 2024: Parties jointly submit a proposed case management plan and
scheduling order
May 24, 2024: All parties appear for an initial status conference

On May 7, the Court adopted the parties proposed briefing schedule for the motion to
dismiss, which contemplates briefing ending by July 8, 2024. DE 11. It is also our understanding
that in conjunction with the motion to dismiss briefing that Plaintiff will file a dispositive motion
of its own which will likely address many of the same issues that will be raised in the motion to
dismiss, collectively the “Dispositive Motions.”
The parties will jointly submit a status letter by May 17 per the Court’s order. However,
because the Dispositive Motions may resolve the case in whole or part, the parties believe they
1

I am counsel for all defendants other than The Governor and Company of the Bank of Ireland (the “Bank of Ireland”).
Counsel for the Bank of Ireland and counsel for plaintiff consent to my writing on their behalf.

1

should be decided first, and then the parties can discuss and submit a proposed case management
plan and scheduling order after. Therefore, we respectfully request that the Court defer any
requirement to submit a proposed case management plan and scheduling order until after the
Dispositive Motions are decided.
As to the May 24 conference, undersigned counsel has a conflict based on a preexisting
court engagement (a federal jury trial in Seattle) and respectfully asks the Court to reschedule the
conference to a date after June 1, assuming the Court still deems the conference necessary.
Respectfully submitted,
Application granted. The parties shall file a joint status letter
no later than May 17, 2024. The parties' deadline to file a
case management plan is adjourned. The initial status
conference originally scheduled for May 24, 2024 is also
adjourned. Following a decision on the Dispositive Motions,
the Court will schedule a deadline for the joint submission of
a case management plan and a date for the status conference,
should they be necessary.
SO ORDERED.
____________________
Hon. Ronnie Abrams
May 10, 2024

/s/ Vincent Levy
Vincent Levy
Michael Shuster
Vincent Levy
Jack Millman
Holwell Shuster & Goldberg LLP
425 Lexington Ave., 14th Floor
New York, New York 10017
Tel: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
Attorneys for Freedom U.S.
Acquisition Corp.; Vispero, S.À.
R.L.; AI Squared In, Inc.; AI2
Holdings Inc.; Algorithmic
Implementations, Inc.; Enhanced
Vision Systems, Inc.; Freedom
Scientific Holdings Corp.; Freedom
Scientific Inc.; Interactive
Accessibility, Inc.; TPG Interactive,
LLC; Optelec U.S. Inc.; Freedom
Scientific BLV Group, LLC;
Optelec GmbH; Optelec Herring
Holdings B.V.; Optelec Holdings
B.V.; and Optelec Nederland B.V.

cc: Counsel for Plaintiff and Defendant Bank of Ireland (via ECF)

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