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Home / Epstein Files / Court Records / Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 1;22-cv-10904 (S.D.N.Y. 2022)
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← Back to Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 1;22-cv-10904 (S.D.N.Y. 2022)

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EXHIBIT A Case Document Filed Page of From Chutter-Ames Hillary To Adam Kern Cc Ellsworth Felicia carol.jacobs doj.vi.gov dackerman motleyrice.com lsinger motleyrice.com Johnson Boyd Butts John smccawley bsfllp.com maria epllc.com andrew.todres ropesgray.com brad epllc.com david.hennes ropesgray.com james.dowden ropesgray.com lisa.bebchick ropesgray.com michael.ardeljan ropesgray.com dboies bsfllp.com brittany epllc.com avillacastin bsfllp.com Subject Doe Deutsche Bank Doe JP Morgan USVI JP Morgan JP Morgan Staley Proposed Revised CMP Dear Mr Kern BDC Tm I am writing on behalf of all parties in the JPMorgan Chase and Deutsche Bank matters in response to the Court 2s direction at last week 2s hearing that the parties discuss new Case Management Plan deadlines and report back to the Court BDC Tm Td BDC Td The parties have conferred but were not able to reach agreement BDC Tm Td Their respective proposals are set forth below BDC Tm Td The primary disputes reflected in these proposals include BDC Tm Whether to have a temporary standstill on depositions and if so how lo ng How long to extend the current fact discovery deadline of April When class certification rebuttal expert reports and briefs should be du Defendants deadlines for responding to the operative complaints BDC Tm The parties would like to address their views with you and will call at p.m today or any other time you prefer BDC Tm Sincerely Hillary BDC Tm BDC Event-4315 Current Deadline-1589 Plaintiffs Proposal-2422 JPMC and DB Proposal Staley Proposal Class Certification Expert Report March March March N/A Class Certification Rebuttal Expert Report March March April N/A Class Certification Reply Expert Report if any March April April N/A Deposition Standstill BDC Tm Until April Until May Staley Response to JPMC Complaint BDC Tm BDC Td April May Motion for Class Certification March April April N/A Requests to Admit-2164 March April April June JPMC and DB Answers to FACs April Affirmative defenses by April April N/A Opposition Brief to Class Certification April April May N/A Fact Discovery closes-2001 April May May July Proponent of a Claim Expert Reports April May May August Reply Brief In Support of Class Certification May May May N/A Opponent of a Claim Expert Reports April May June August Case Document Filed Page of Complete Expert Depositions April June June August Summary Judgment Motions May June June September Summary Judgment Responses May June July September Summary Judgment Replies June July July September Pre-Trial Conference June July days before trial October Hillary Chutter-Ames WilmerHale she/her/hers World Trade Center Greenwich Street New York NY USA hillary.chutter-ames wilmerhale.com Please consider the environment before printing this email This email message and any attachments are being sent by Wilmer Cutler ickering Hale and Dorr LLP are confidential and may be privileged If you are not the intended recipient please notify us immediately replying to this message or by sending an email to postmaster wilmerhale.com 227and destroy all copies of this message and any attachments Thank you For more information about WilmerHale please visit us at http://w.wilmerhale.com Case Document Filed Page of
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