gov.uscourts.nysd.447706.639.0.pdf

Case 1:15-cv-07433-LAP Document 639 Filed 02/22/17 Page 1 of 2 Haddon , Morgan and Foreman, P.c Jeffrey S. Pagliuca HADDON MORGAN 150 East l 0th Avenue FOREMA N Den ver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com jpagl[[email protected] r 11- ·~ ~u-~·7 j ,-:..~ ~ ·s I ; I February 21, 2017 F Via Email Hon. Robert W. Sweet ·-. United States District Judge United States District Court Daniel Patrick Moynihan Courthouse Southern District of New York 500 Pearl Street, Room 1940 New York, New York 10007-1312 Re: Giuffre v. Maxwell, 15-cv-07433-RWS Dear Judge Sweet: The parties write jointly to request that the Court vacate the hearing to rule on deposition objections currently scheduled for this Thursday, February 23 , 2017, to a date after the Court enters rulings on other pending motions for the following reasons. A number of legal issues currently before the Court will likely impact various portions of deposition testimony designated by the parties. In addition, the parties shortly will be filing motions in limine that also will impact the designated testimony. See ECF 455 at 2. In the interests of judicial economy, the parties believe it would be appropriate to have the benefit of the Court's rulings on these other issues, review the designated testimony in light of such rulings and then address any unresolved designation objections. The parties expect to submit in the next few days a proposed schedule for hearings on remaining legal issues in this matter and a revised proposed scheduling order in light of the new anticipated trial date of May 15, 2017. Accordingly, the parties request that the Court vacate the hearing scheduled for consistent with the Court's schedule. s February 23, 2017 in this case to be rescheduled by agreement of the parties and ,::» ~f ??~ c.b~f)d -:k. · 2-2 ·17 Case 1:15-cv-07433-LAP Document 639 Filed 02/22/17 Page 2 of 2 Hon. Robert W. Sweet February 21, 2017 Page 2 Respectfully Submitted, FARMER, JAFFE, WEISSING, EDWARDS, HADDON, MORGAN AND FOREMAN, P.C . FISTOS & LEHRMAN Isl Bradley J Edwards Isl Jeffrey S. Pagliuca Bradley J. Edwards Jeffrey S. Pagliuca CERTIFICATE OF SERVICE I certify that on February 21 , 2017, I electronically served this LETTER MOTION via ELECTRONIC MAIL on the following: Sigrid S. Mccawley Paul G. Cassell Meredith Schultz 383 S. University Street BOIES, SCHILLER & FLEXNER, LLP Salt Lake City, UT 84112 401 East Las Olas Boulevard, Ste. 1200 [email protected] Ft. Lauderdale, FL 33301 [email protected] [email protected] J. Stanley Pottinger Bradley J. Edwards 49 Twin Lakes Rd. FARMER, JAFFE, WEIS SING, EDWARDS, FISTOS South Salem, NY 10590 & LEHRMAN, P.L. [email protected] 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 [email protected] Isl Nicole Simmons Nicole Simmons