EXHIBIT A¶
From: Chimer-Ames KIWI To: Adam Kern Cc FIsocrth Frlicia H;Slam u am; Farktrmamarroatlemcr corn; BlaiNSI0SSICara202; ealla13; sorraMovvitsfao corn’ MADOPFarOM’ Dorkrav todommrecomrav caw IBacaparssa; CIMAIXODInginpOSBarSOM; kintlamicanunumuatli; labektellaconaitanco; msbaelaurIclua2mccausan; slosegthstlIgsmn; marg.-or maarasonaltsflha row Sobtoct: Doe v. Deutsche Bank; Doe v. W USVI v. JP = JP =v. Staley: Proposed Revesed CHP¶
Dear Mr. Kern:¶
I am writing on behalf of all parties in the JPMorgan Chase and Deutsche Bank matters in response to the Court’s direction at last week’s hearing that the parties discuss new Case Management Plan deadlines and report back to the Court.¶
The parties have conferred, but were not able to reach agreement. Their respective proposals are set forth below. The primary disputes reflected in these proposals include:¶
- Whether to have a temporary standstill on depositions, and if so, how long?
- How long to extend the current fact discovery deadline of April 24?
- When class certification rebuttal expert reports and briefs should be due?
- Defendants’ deadlines for responding to the operative complaints
The parties would like to address their views with you and will call at 1:30 p.m. today or any other time you prefer.¶
Sincerely, Hillary¶
| Event Current Deadline | Plaintiffs’ Proposal | JPMC and DB | |
|---|---|---|---|
| March 1, 2023 | March 1, 2023 | March 1, 2023 | N/A |
| March 16, 2023 | March 23, 2023 | April 13, 2023 | N/A |
| March 27, 2023 | April 3, 2023 | April 24, 2023 | N/A |
| Deposition Standstill | None | Until April 3, 2023 | Until May 31, 2023 |
| April 10, 2023 | May 8, 2023 | ||
| March 31, 2023 | April 7, 2023 | April 28, 2023 | N/A |
| Requests to Admit March 17, 2023 | April 7, 2023 | April 17, 2023 | June 30, 2023 |
| April 3, 2023 | Affirmative defenses | ||
| April 17, 2023 | N/A | ||
| April 21, 2023 | April 28, 2023 | May 19, 2023 | N/A |
| Fact Discovery closes April 24, 2023 | May 1, 2023 | May 22, 2023 | July 31, 2023 |
| April 4, 2023 | May 9, 2023 | May 26, 2023 | August 7, 2023 |
| May 5, 2023 | May 12, 2023 | May 29, 2023 | N/A |
| April 18, 2023 | May 23, 2023 | June 9, 2023 | August 21, 2023 |
| April 24, 2023 | June 5, 2023 | June 16, 2023 | August 28, 2023 |
|---|---|---|---|
| May 1, 2023 | June 9, 2023 | June 19, 2023 | September 8, 2023 |
| May 22, 2023 | June 30, 2023 | July 10, 2023 | September 22, 2023 |
| June 5, 2023 | July 14, 2023 | July 20, 2023 | September 29, 2023 |
| Pre-Trial Conference June 12, 2023 | July 24, 2023 | 30 days before trial | October 6, 2023 |
Hillary Chutter•Ames I WilmerHale¶
she/her/hers¶
7 World Trade Center¶
250 Greenwich Street¶
New York, NY 10007 USA¶
+1 212 230 8848 (t)¶
+1 212 230 8888)f)¶
binary chutter-ames@wilmerhale.rom¶
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