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 confe rence 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)

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425 Lexington Ave., 14th Floor New York, New York 10017 Tel: (646) 837-5151 Fax: (646) 837-5150 www.hsgllp.com Vincent Levy (646) 837-5120 vlevy@hsgllp.com 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):    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: (646) 837-5151 Email: mshuster@hsgllp.com vlevy@hsgllp.com jmillman@hsgllp.com 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) 2

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