The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings
Petitioner: Louis Bacon
Respondent: Stephen J. Feralio
In Re: The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings
Interested Party: Nygard International Partnership, Nygard International Inc. and Nygard Inc.
Case Number: 1:2014mc00258
Filed: August 13, 2014
Court: US District Court for the Southern District of New York
Office: Foley Square Office
County: New York
Presiding Judge: Denise L Cote
Nature of Suit: Other
Cause of Action: M 77 Application to have subpoena issued to person living in this district re: action in foreign cou
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This docket was last retrieved on September 1, 2017. A more recent docket listing may be available from PACER.

Date Filed Document Text
September 1, 2017 Opinion or Order Filing 151 ORDER: Due to inactivity in this action since January 22, 2015, and pursuant to the Courts July 25 order, it is hereby ORDERED that the above-captioned action be, and hereby is, closed. The Clerk of Court shall close this case. (Signed by Judge Denise L. Cote on 9/1/2017) (gr)
July 26, 2017 Opinion or Order Filing 150 ENDORSED LETTER addressed to Judge Denise L. Cote from William Christopher Carmody dated July 25, 2017 re: Administratively Closing Case. ENDORSEMENT: This action shall be closed on 9/1/17 unless there is a further dispute brought before that date that requires this Court's attention. (Signed by Judge Denise L. Cote on 7/25/2017) (gr)
July 25, 2017 Opinion or Order Filing 149 LETTER addressed to Judge Denise L. Cote from William Christopher Carmody dated July 25, 2017 re: Administratively Closing Case. Document filed by Louis Bacon.(Carmody, William)
April 20, 2017 Opinion or Order Filing 148 ENDORSED LETTER addressed to Judge Denise L. Cote from Stephen Schackelford, Jr. dated 4/17/2017 re: Seeking Court's assistance to resolve disputed confidentiality designations and to clarify the governing Protective Order. ENDORSEMENT: The application to amend the Protective Order is denied. Its terms apply whether or not a document is used in cross-examination. (Signed by Judge Denise L. Cote on 4/20/2017) (gr)
April 19, 2017 Opinion or Order Filing 147 LETTER addressed to Judge Denise L. Cote from Aaron H. Marks dated April 18, 2017 re: Writing in Response to Petitioner's April 14, 2017 Letter. Document filed by Nygard Inc., Nygard International Inc., Nygard International Partnership.(Marks, Aaron)
April 19, 2017 Opinion or Order Filing 146 LETTER addressed to Judge Denise L. Cote from Aaron H. Marks dated April 18, 2017 re: Writing in Response to Petitioner's April 14, 2017 Letter Motion. Document filed by Nygard Inc., Nygard International Inc., Nygard International Partnership.(Marks, Aaron)
April 17, 2017 Opinion or Order Filing 145 SEALED DOCUMENT placed in vault.(rz)
April 17, 2017 Opinion or Order Filing 144 LETTER MOTION for Discovery re disputed confidentiality designations and to clarify the governing Protective Order addressed to Judge Denise L. Cote from Stephen Shackelford, Jr. dated 04/17/2017. Document filed by Louis Bacon. (Attachments: #1 Exhibit 1, #2 Exhibit 2 (1 of 4), #3 Exhibit 2 (2 of 4), #4 Exhibit 2 (3 of 4), #5 Exhibit 2 (4 of 4), #6 Exhibit 3, #7 Exhibit 4, #8 Exhibit 5, #9 Exhibit 6, #10 Exhibit 7, #11 Exhibit 8, #12 Exhibit 9, #13 Exhibit 10, #14 Exhibit 11, #15 Exhibit 12, #16 Exhibit 13, #17 Exhibit 14, #18 Exhibit 15, #19 Exhibit 15)(Shackelford, Stephen)
April 17, 2017 Opinion or Order Filing 143 NOTICE of Change of Firm Name to Kasowitz Benson Torres LLP. Document filed by Nygard Inc., Nygard International Inc., Nygard International Partnership. (Marks, Aaron)
April 17, 2017 Opinion or Order Filing 142 ENDORSED LETTER addressed to Judge Denise L. Cote from Stephen Shackelford, Jr. dated April 14, 2017 re: motion to seal document and exhibits. ENDORSEMENT: The documents accompanying the letter may be sealed. The letter should be filed in unredacted from. Any response is due by 4/19/17. (Signed by Judge Denise L. Cote on 4/17/2017) (gr) Modified on 4/18/2017 (gr). Modified on 4/18/2017 (gr).
April 14, 2017 Opinion or Order Filing 141 LETTER MOTION to Seal Document and Exhibits addressed to Judge Denise L. Cote from Stephen Shackelford, Jr. dated April 14, 2017. Document filed by Louis Bacon.(Shackelford, Stephen)
April 14, 2017 Opinion or Order Filing 140 NOTICE OF CHANGE OF ADDRESS by Sharon Anne O'Shaughnessy on behalf of Stephen J. Feralio. New Address: Murphy & McGonigle, P.C., 1185 Avenue of the Americas, 21st Floor, New York, New York, USA 10036, 212-880-3990. (O'Shaughnessy, Sharon)
February 13, 2017 Opinion or Order Filing 139 NOTICE OF APPEARANCE by Mark P. Musico on behalf of Louis Bacon. (Musico, Mark)
February 13, 2017 Opinion or Order Filing 138 NOTICE OF APPEARANCE by Stephen Shackelford, Jr on behalf of Louis Bacon. (Shackelford, Stephen)
February 13, 2017 Opinion or Order Filing 137 NOTICE OF APPEARANCE by Jacob W Buchdahl on behalf of Louis Bacon. (Buchdahl, Jacob)
February 13, 2017 Opinion or Order Filing 136 NOTICE OF APPEARANCE by William Christopher Carmody on behalf of Louis Bacon. (Carmody, William)
February 13, 2017 Opinion or Order Filing 135 MEMO ENDORSEMENT granting #134 Letter Motion to Reopen this action. (Signed by Judge Denise L. Cote on 2/13/2017) (gr)
February 10, 2017 Opinion or Order Filing 134 LETTER MOTION to Reopen addressed to Judge Denise L. Cote from William Christopher Carmody dated February 10, 2017. Document filed by Louis Bacon.(Carmody, William)
October 6, 2015 Opinion or Order Filing 133 ORDER: Due to inactivity in this action since January 22, 2015, it is hereby ORDERED that the above-captioned action be, and hereby is closed. The Clerk of Court shall close this case. (Signed by Judge Denise L. Cote on 10/6/2015) (gr)
January 22, 2015 Opinion or Order Filing 132 NOTICE OF CHANGE OF ADDRESS by Steven David Feldman on behalf of Stephen J. Feralio. New Address: Murphy & McGonigle, P.C., 1185 Avenue of the Americas, 21st Floor, New York, New York, USA 10036, 212-880-3988. (Feldman, Steven)
January 12, 2015 Opinion or Order Filing 131 ENDORSED LETTER addressed to Judge Denise L. Cote from Orin Snyder dated January 7, 2014 re: request for order modification. ENDORSEMENT: Denied. (Signed by Judge Denise L. Cote on 1/12/2015) (gr)
January 12, 2015 Opinion or Order Filing 130 LETTER addressed to Judge Denise L. Cote from Aaron H. Marks dated January 12, 2015 re: Protective Order. Document filed by Nygard Inc., Nygard International Inc., Nygard International Partnership.(Marks, Aaron)
January 7, 2015 Opinion or Order Filing 129 LETTER addressed to Judge Denise L. Cote from Orin Snyder dated January 7, 2014 re: request for order modification. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Attachment - Jenny Afia Declaration, #2 Attachment - Robert Adams Declaration)(Snyder, Orin)
December 15, 2014 Opinion or Order Filing 128 MEMO ENDORSEMENT regarding #126 Letter Motion for judicial intervention regarding responsive files that Nygard International Partnership and Nygard Inc. refuse to produce to Petitioners. ENDORSEMENT: The Nygard Parties' request to not require production is denied. They shall promptly review and produce it. (Signed by Judge Denise L. Cote on 12/15/2014) (gr)
December 12, 2014 Opinion or Order Filing 127 LETTER addressed to Judge Denise L. Cote from Orin Snyder dated December 12, 2014 re: response to the Nygard Parties' letter of December 11, 2014. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings.(Snyder, Orin)
December 12, 2014 Opinion or Order Filing 126 FILING ERROR - WRONG EVENT TYPE SELECTED FROM MENU - LETTER MOTION for Conference Request for Judicial Intervention Regarding Files Responsive to Amended Subpoena addressed to Judge Denise L. Cote from Steven D. Feldman dated December 12, 2014. Document filed by Stephen J. Feralio. (Attachments: #1 Exhibit One, #2 Exhibit Two, #3 Exhibit Three, #4 Exhibit Four, #5 Exhibit Five)(Feldman, Steven) Modified on 12/15/2014 (db).
December 12, 2014 Opinion or Order Filing 125 MEMO ENDORSEMENT granting #124 Letter Motion for Leave to File Excess Pages. (Signed by Judge Denise L. Cote on 12/12/2014) (gr)
December 11, 2014 Opinion or Order Filing 124 LETTER MOTION for Leave to File Excess Pages One Additonal Page addressed to Judge Denise L. Cote from Steven D. Feldman dated December 11, 2014. Document filed by Stephen J. Feralio.(Feldman, Steven)
December 11, 2014 Opinion or Order Filing 123 LETTER addressed to Judge Denise L. Cote from Aaron H. Marks dated 12/11/2014 re: the production drive received from Feralio on December 4, 2014. Document filed by Nygard Inc., Nygard International Inc., Nygard International Partnership. (Attachments: #1 Exhibit A, #2 Exhibit B)(Marks, Aaron)
December 5, 2014 Opinion or Order Filing 122 ENDORSED LETTER addressed to Judge Denise L. Cote from Steven D. Feldman dated December 4, 2014 re: Given that we have completed our review and production of electronic files responsive to the Amended Subpoena, we respectfully request the Court's permission to cease providing weekly updates on our progress. ENDORSEMENT: Granted. (Signed by Judge Denise L. Cote on 12/5/2014) (gr)
December 5, 2014 Opinion or Order Filing 121 LETTER addressed to Judge Denise L. Cote from Steven D. Feldman dated December 4, 2014 re: Weekly Report. Document filed by Stephen J. Feralio.(Feldman, Steven)
December 3, 2014 Opinion or Order Filing 120 ENDORSED LETTER addressed to Judge Denise L. Cote from Orin Snyder dated December 3, 2014 re: Response to the Nygard Parties' letter of December 2, 2014. ENDORSEMENT: The request in the 11/26 letter is denied. The parties shall meet and confer before raising any future disputes with the Court. (Signed by Judge Denise L. Cote on 12/3/2014) (gr)
December 3, 2014 Opinion or Order Filing 119 LETTER addressed to Judge Denise L. Cote from Orin Snyder dated December 3, 2014 re: Response to Nygard Parties Letter of December 2, 2014. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Exhibit A, #2 Exhibit B)(Snyder, Orin)
December 3, 2014 Opinion or Order Filing 118 FILING ERROR - DEFICIENT DOCKET ENTRY (SEE DOCUMENT #119) - LETTER addressed to Judge Denise L. Cote from Orin Snyder dated December 3, 2014 re: Response to the Nygard Parties' letter of December 2, 2014.. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Exhibit A, #2 Exhibit B)(Snyder, Orin) Modified on 12/3/2014 (ldi).
December 2, 2014 Opinion or Order Filing 117 LETTER addressed to Judge Denise L. Cote from Aaron H. Marks dated 12/2/2014 re: Petitioners' November 26, 2014 letter. Document filed by Nygard Inc., Nygard International Inc., Nygard International Partnership.(Marks, Aaron)
November 27, 2014 Opinion or Order Filing 115 LETTER addressed to Judge Denise L. Cote from Steven D. Feldman dated November 27, 2014 re: Weekly Report. Document filed by Stephen J. Feralio.(Feldman, Steven)
November 26, 2014 Opinion or Order Filing 116 SEALED DOCUMENT placed in vault.(rz)
November 26, 2014 Opinion or Order Filing 114 LETTER addressed to Judge Denise L. Cote from Orin Snyder dated November 26, 2014 re: production violations. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Exhibit A through J)(Snyder, Orin)
November 21, 2014 Opinion or Order Filing 113 ENDORSED LETTER addressed to Judge Denise L. Cote from Steven D. Feldman dated November 20, 2014 re: Weekly Report. ENDORSEMENT: Approved. (Signed by Judge Denise L. Cote on 11/21/2014) (gr)
November 20, 2014 Opinion or Order Filing 112 LETTER addressed to Judge Denise L. Cote from Steven D. Feldman dated November 20, 2014 re: Weekly Report. Document filed by Stephen J. Feralio.(Feldman, Steven)
November 14, 2014 Opinion or Order Filing 111 MEMO ENDORSEMENT regarding #108 Letter Motion for Extension of Time to Review materials received until 12/2/2014. ENDORSEMENT: Schedule modification is approved. (Signed by Judge Denise L. Cote on 11/14/2014) (gr)
November 13, 2014 Opinion or Order Filing 110 LETTER addressed to Judge Denise L. Cote from Steven D. Feldman dated 11/13/14 re: weekly report on production. Document filed by Stephen J. Feralio.(Feldman, Steven)
November 13, 2014 Opinion or Order Filing 109 LETTER addressed to Judge Denise L. Cote from Aaron H. Marks dated 11/13/2014 re: in response to Respondent counsel's November 12, 2014 letter regarding an extension of time. Document filed by Nygard Inc., Nygard International Inc., Nygard International Partnership.(Marks, Aaron)
November 12, 2014 Opinion or Order Filing 108 LETTER MOTION for Extension of Time to Complete Review and Production addressed to Judge Denise L. Cote from Steven D. Feldman dated November 12, 2014. Document filed by Stephen J. Feralio.(Feldman, Steven)
November 6, 2014 Opinion or Order Filing 107 LETTER addressed to Judge Denise L. Cote from Steven D. Feldman dated November 6, 2014 re: weekly report on production. Document filed by Stephen J. Feralio.(Feldman, Steven)
November 3, 2014 Opinion or Order Filing 106 ORDER REGARDING AMENDED SUBPOENA FOR DOCUMENTS FROM STEPHEN FERALIO (Signed by Judge Denise L. Cote on 11/3/2014) (gr)
October 31, 2014 Opinion or Order Filing 105 LETTER addressed to Judge Denise L. Cote from Avi Weitzman dated October 31, 2014 re: proposed order for the narrowing of the subpoena. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Text of Proposed Order, #2 Exhibit A (Amended))(Weitzman, Avi)
October 31, 2014 Opinion or Order Filing 104 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a conference proceeding held on 10/23/2014 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly)
October 31, 2014 Opinion or Order Filing 103 TRANSCRIPT of Proceedings re: conference held on 10/23/2014 before Judge Denise L. Cote. Court Reporter/Transcriber: Rose Prater, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 11/24/2014. Redacted Transcript Deadline set for 12/4/2014. Release of Transcript Restriction set for 2/1/2015.(McGuirk, Kelly)
October 30, 2014 Opinion or Order Filing 102 LETTER addressed to Judge Denise L. Cote from Steven D. Feldman dated October 30, 2014 re: weekly report on production. Document filed by Stephen J. Feralio.(Feldman, Steven)
October 28, 2014 Opinion or Order Filing 101 ORDER: In conjunction with the October 28, 2014 Opinion and Order granting the 28 U.S.C. 1782 application, and pursuant to the October 28, 2014 on-the-record telephone conference held in this matter, it is herebyORDERED that Feralio shall complete his production to the Nygrd parties by November 14, 2014. (See Order for rest of schedule.) (Signed by Judge Denise L. Cote on 10/28/2014) (gr)
October 28, 2014 Opinion or Order Filing 100 OPINION AND ORDER #104927....Having considered the factors that the law requires, the Court chooses to exercise its discretion to grant the 1782 petition. During the October 23 telephone conference, petitioners, Feralio, and the Nygrd parties committed to meet and confer to reach agreement on the appropriate scope of the subpoena that would issue upon a grant of the 1782 petition. At a subsequent on-the-record telephone conference on October 28, the Court issued rulings on the remaining points of disagreement with respect to the scope of the subpoena. The Court also set out a procedure, reflected in an Order to be issued in conjunction with this Opinion, governing production of the subpoenaed material. (Signed by Judge Denise L. Cote on 10/28/2014) (gr) Modified on 11/4/2014 (soh).
October 28, 2014 Opinion or Order Filing 99 LETTER addressed to Judge Denise L. Cote from Aaron H. Marks dated October 28, 2014 re: subpoena scope. Document filed by Nygard Inc., Nygard International Inc., Nygard International Partnership. (Attachments: #1 Exhibit A)(Marks, Aaron)
October 28, 2014 Opinion or Order Minute Entry for proceedings held before Judge Denise L. Cote: Telephone Conference held on 10/28/2014. (Court Reporter Michael McDaniel) (gr)
October 27, 2014 Opinion or Order Filing 98 LETTER addressed to Judge Denise L. Cote from Avi Weitzman dated October 27, 2014 re: objection to additional letter submission. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings.(Weitzman, Avi)
October 27, 2014 Opinion or Order Filing 97 MEMO ENDORSEMENT regarding #96 Letter Motion to Adjourn Conference. ENDORSEMENT: The conference shall occur at 2:30 pm on Oct. 28.(Telephone Conference set for 10/28/2014 at 02:30 PM before Judge Denise L. Cote.) (Signed by Judge Denise L. Cote on 10/27/2014) (gr)
October 27, 2014 Opinion or Order Filing 96 LETTER MOTION to Adjourn Conference Call from 10/27/14 to 10/28/14, addressed to Judge Denise L. Cote from Aaron H. Marks dated 10/27/14. Document filed by Nygard Inc., Nygard International Inc., Nygard International Partnership.(Marks, Aaron)
October 27, 2014 Opinion or Order Filing 95 LETTER addressed to Judge Denise L. Cote from Avi Weitzman dated October 27, 2014 re: Parties' Meet and Confer Status. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H)(Snyder, Orin)
October 23, 2014 Opinion or Order Filing 94 LETTER addressed to Judge Denise L. Cote from Steven D. Feldman dated October 23, 2014 re: weekly report on production. Document filed by Stephen J. Feralio.(Feldman, Steven)
October 22, 2014 Opinion or Order Filing 93 LETTER addressed to Judge Denise L. Cote from Orin Snyder dated October 22, 2014 re: Response to October 20, 2014 Letter by Nygard Parties. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C)(Snyder, Orin)
October 22, 2014 Opinion or Order Filing 92 LETTER addressed to Judge Denise L. Cote from Steven D. Feldman dated October 22, 2014 re: response to October 20, 2014 letter. Document filed by Stephen J. Feralio.(Feldman, Steven)
October 20, 2014 Opinion or Order Filing 91 LETTER addressed to Judge Denise L. Cote from Marc E. Kasowitz dated October 20, 2014 re: the Court's October 2, 2014 Order. Document filed by Nygard Inc., Nygard International Partnership. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C)(Kasowitz, Marc)
October 16, 2014 Opinion or Order Filing 90 LETTER addressed to Judge Denise L. Cote from Steven D. Feldman dated October 16, 2014 re: weekly report on production. Document filed by Stephen J. Feralio.(Feldman, Steven)
October 9, 2014 Opinion or Order Filing 89 LETTER addressed to Judge Denise L. Cote from Steven D. Feldman dated October 9, 2014 re: weekly report on production. Document filed by Stephen J. Feralio.(Feldman, Steven)
October 3, 2014 Opinion or Order Filing 88 SEALED DOCUMENT placed in vault.(mps)
October 2, 2014 Opinion or Order Filing 87 ENDORSED LETTER addressed to Judge Denise L. Cote from Stephen Feldman dated 10/2/2014 updating the Court regarding Respondent Stephen J. Feralio's efforts to review and produce materials to Nygard International Partnership and Nygard Inc. responsive to the subpoena issued by Petitioners, The Coalition to Protect Clifton Bay and Louis Bacon. ENDORSEMENT: The parties and Mr. Feldman shall discuss whether there should be a system that Feralio should adopt to organize and prioritize his review. (Signed by Judge Denise L. Cote on 10/2/2014) (gr)
October 2, 2014 Opinion or Order Filing 86 LETTER addressed to Judge Denise L. Cote Document filed by Stephen J. Feralio.(Feldman, Steven)
October 1, 2014 Opinion or Order Filing 85 LETTER addressed to Judge Denise L. Cote from Orin Snyder dated September 10, 2014 re: Response to Nygard September 10, 2014 Letter. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings.(Snyder, Orin)
September 30, 2014 Opinion or Order Filing 84 ORDER...the hearing currently scheduled for October 7, 2014 is adjourned sine die. (Signed by Judge Denise L. Cote on 9/30/2014) (gr)
September 30, 2014 Opinion or Order Filing 83 DECLARATION of JACK PALLADINO in Support re: #1 MOTION Ex Parte Application for the Issuance of Subpoenas Duce Tecum and AD TESTIFICANDUM pursuant to 28 U.S.C. 1782 to Conduct Discovery for use in Foreign Proceedings.. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5)(Snyder, Orin)
September 30, 2014 Opinion or Order Filing 82 DECLARATION of STEPHEN J. FERALIO in Support re: #1 MOTION Ex Parte Application for the Issuance of Subpoenas Duce Tecum and AD TESTIFICANDUM pursuant to 28 U.S.C. 1782 to Conduct Discovery for use in Foreign Proceedings.. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Exhibit 1)(Snyder, Orin)
September 30, 2014 Opinion or Order Filing 81 DECLARATION of JENNY AFIA in Support re: #1 MOTION Ex Parte Application for the Issuance of Subpoenas Duce Tecum and AD TESTIFICANDUM pursuant to 28 U.S.C. 1782 to Conduct Discovery for use in Foreign Proceedings.. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Snyder, Orin)
September 30, 2014 Opinion or Order Filing 80 MEMORANDUM OF LAW in Support re: #1 MOTION Ex Parte Application for the Issuance of Subpoenas Duce Tecum and AD TESTIFICANDUM pursuant to 28 U.S.C. 1782 to Conduct Discovery for use in Foreign Proceedings. . Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Snyder, Orin)
September 30, 2014 Opinion or Order Filing 79 LETTER addressed to Judge J. Paul Oetken from Orin Snyder dated September 5, 2014 re: Recent Nygar Actions. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D)(Snyder, Orin)
September 30, 2014 Opinion or Order Filing 78 LETTER addressed to Judge Denise L. Cote from Marc E. Kasowitz dated 9/10/2014 re: (Redacted) Letter response to Petitioners 9/5/14 letter. Document filed by Nygard Inc., Nygard International Inc., Nygard International Partnership. (Attachments: #1 Exhibit A-Redacted, #2 Exhibit B-Redacted)(Kasowitz, Marc)
September 29, 2014 Opinion or Order Filing 77 ORDER TO STRIKE: As set forth within, it is hereby ORDERED that the Nygard Parties' request to file publicly in an unredacted form certain portions of their letter of September 10, 2014 (filed under seal) - specifically, footnote 12 on page 11 and exhibit B attached to that letter (except for any names of any non-parties to this action, which should remain redacted) - is GRANTED; It is hereby further ORDERED that (A) the Clerk of the Court shall immediately strike the following documents from the docket of the Section 1782 Action; (B) the Parties shall publicly file redacted versions of the following documents in accordance with the Court's September 17, 2014 Order; and (C) for each of the following documents, the Parties shall file under seal an unredacted copy of any page of such documents that contains a redaction in the publicly-filed version of that document: (1) Petitioner's Memorandum of Law, dated August 13, 2014, Docket No. 2; (2) Jenny Afia Declaration, dated August 13, 2014, Docket No. 3; (3) Stephen J.Feralio Declaration, dated August 13, 2014, Docket No. 4; and (4) Jack Palladino Declaration, dated August 13, 2014, Docket No. 5; It is hereby further ORDERED that (A) the Parties shall publicly file redacted versions of the following documents in accordance with the Court's September 17, 2014 Order and this Order; and (B) for each of the following documents, the Parties shall file under seal an unredacted copy of any page of such documents that contains a redaction in the publicly-filed version of that document: (1) Petitioners' Under Seal Letter of September 5, 2014 and its exhibits; and (2) The Nygard Companies' Under Seal Letter of September 10, 2014 and its exhibits. SO ORDERED. (See Order.) (Signed by Judge Denise L. Cote on 9/29/2014) (ajs)
September 29, 2014 Opinion or Order Filing 76 ENDORSED LETTER addressed to Judge Denise L. Cote from Avi Weitzman dated 9/24/2014 re: Petitioners' request for redactions regarding its Memorandum of Law and supporting declarations..... ENDORSEMENT: Approved. (Signed by Judge Denise L. Cote on 9/29/2014) (gr)
September 29, 2014 Opinion or Order Filing 75 ENDORSED LETTER addressed to Judge Denise L. Cote from Orin Snyder dated September 24, 2014 re: Permission to file redacted documents. ENDORSEMENT: Approved. (Signed by Judge Denise L. Cote on 9/29/2014) (gr)
September 29, 2014 Opinion or Order Filing 74 LETTER addressed to Judge Denise L. Cote from Orin Snyder dated 9/22/2014 re: Petitioners' letter setting forth its positions on the Draft Protective Order. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings.(gr)
September 29, 2014 Opinion or Order Filing 73 LETTER addressed to Judge Denise L. Cote from Marc E. Kasowitz dated 9/23/2014 re: Letter in response to the Court's September 17, 2014 Memo Endorsed Order. Document filed by Nygard Inc., Nygard International Inc., Nygard International Partnership.(gr)
September 29, 2014 Opinion or Order Filing 72 PROTECTIVE ORDER...regarding procedures to be followed that shall govern the handling of confidential material... (Signed by Judge Denise L. Cote on 9/29/2014) (gr)
September 29, 2014 Opinion or Order Filing 71 DECLARATION of Daane Clifford (Supplemental) in Support re: #46 MOTION to Intervene .. Document filed by Nygard Inc., Nygard International Partnership. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D)(Marks, Aaron)
September 29, 2014 Opinion or Order Filing 70 REPLY MEMORANDUM OF LAW in Support re: #46 MOTION to Intervene . and Opposition to 28 U.S.C. Section 1782 Application and to Quash Subpoena. Document filed by Nygard Inc., Nygard International Partnership. (Marks, Aaron)
September 29, 2014 Opinion or Order Filing 69 DECLARATION of Daane Clifford (CORRECTED) in Support re: #46 MOTION to Intervene .. Document filed by Nygard Inc., Nygard International Partnership. (Kasowitz, Marc)
September 29, 2014 Opinion or Order Filing 68 LETTER addressed to Judge Denise L. Cote from Marc E. Kasowitz dated September 29, 2014 re: Corrected Clifford Declaration. Document filed by Nygard Inc., Nygard International Partnership.(Kasowitz, Marc)
September 25, 2014 Opinion or Order Filing 67 LETTER addressed to Judge Denise L. Cote from Steven D. Feldman dated September 25, 2014 re: weekly report on production. Document filed by Stephen J. Feralio.(Feldman, Steven)
September 25, 2014 Opinion or Order Filing 66 DECLARATION of STEPHEN J. FERALIO in Support re: #62 Memorandum of Law,,. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E)(Snyder, Orin)
September 25, 2014 Opinion or Order Filing 65 DECLARATION of AVI WEITZMAN in Support re: #62 Memorandum of Law,,. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M, #14 Exhibit N, #15 Exhibit O, #16 Exhibit P, #17 Exhibit Q)(Snyder, Orin)
September 25, 2014 Opinion or Order Filing 64 DECLARATION of FREDERICK R. SMITH in Support re: #62 Memorandum of Law,,. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F)(Snyder, Orin)
September 25, 2014 Opinion or Order Filing 63 DECLARATION of ROBERT K. ADAMS re: #62 Memorandum of Law,, . Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E)(Snyder, Orin)
September 25, 2014 Opinion or Order Filing 62 MEMORANDUM OF LAW re: #46 MOTION to Intervene ., #1 MOTION Ex Parte Application for the Issuance of Subpoenas Duce Tecum and AD TESTIFICANDUM pursuant to 28 U.S.C. 1782 to Conduct Discovery for use in Foreign Proceedings. SUPPLEMENTAL MEMORANDUM OF LAW IN SUPPORT OF 28 U.S.C. 1782 APPLICATION AND IN OPPOSITION TO MOTION TO INTERVENE AND TO QUASH SUBPOENAS. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Snyder, Orin)
September 24, 2014 Opinion or Order Filing 61 LETTER addressed to Judge Denise L. Cote from Orin Snyder dated September 24, 2014 re: Permission to file redacted documents. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings.(Snyder, Orin)
September 23, 2014 Opinion or Order Filing 60 ENDORSED LETTER addressed to Judge Denise L. Cote from Avi Weitzman dated September 22, 2014 re: extension. ENDORSEMENT: Granted. (Signed by Judge Denise L. Cote on 9/23/2014) (gr)
September 22, 2014 Opinion or Order Filing 59 LETTER addressed to Judge Denise L. Cote from Marc E. Kasowitz dated September 22, 2014 re: the Court's September 11, 2014 Order, advising that the parties have met and conferred regarding a proposed Protective Order concerning discovery, if any, in this Action. Document filed by Nygard Inc., Nygard International Partnership.(Kasowitz, Marc)
September 22, 2014 Opinion or Order Filing 58 LETTER addressed to Judge Denise L. Cote from Avi Weitzman dated September 22, 2014 re: extension. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings.(Snyder, Orin)
September 22, 2014 Opinion or Order Filing 57 LETTER addressed to Judge Denise L. Cote from Orin Snyder dated September 22, 2014 re: draft Protective Order. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Exhibit 1)(Snyder, Orin)
September 22, 2014 Opinion or Order Filing 56 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a conference proceeding held on 9/11/14 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly)
September 22, 2014 Opinion or Order Filing 55 TRANSCRIPT of Proceedings re: conference held on 9/11/2014 before Judge Denise L. Cote. Court Reporter/Transcriber: Ann Hairston, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 10/17/2014. Redacted Transcript Deadline set for 10/27/2014. Release of Transcript Restriction set for 12/29/2014.(McGuirk, Kelly)
September 22, 2014 Opinion or Order Filing 54 ENDORSED LETTER addressed to Judge Denise L. Cote from Avi Weitzman dated 9/19/2014 re: Status Update. ENDORSEMENT: Granted. (Signed by Judge Denise L. Cote on 9/22/2014) (gr)
September 19, 2014 Opinion or Order Filing 53 LETTER addressed to Judge Denise L. Cote from Avi Weitzman dated 9/19/2014 re: Status Update. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings.(Weitzman, Avi)
September 19, 2014 Opinion or Order Filing 52 LETTER addressed to Judge Denise L. Cote from Orin Snyder dated September 19, 2014 re: Response to Sept. 18, 2014 Letter. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings.(Snyder, Orin)
September 19, 2014 Opinion or Order Filing 51 LETTER addressed to Judge Denise L. Cote from Marc E. Kasowitz dated September 18, 2014 re: proper context to the assertions in Petitioners' September 18, 2014 letter concerning the litigation that the Nygard Companies filed in the California action. Document filed by Nygard Inc., Nygard International Inc., Nygard International Partnership.(Kasowitz, Marc)
September 19, 2014 Opinion or Order Filing 50 DECLARATION of Thomas A. E. Evans in Support re: #46 MOTION to Intervene .. Document filed by Nygard Inc., Nygard International Inc., Nygard International Partnership. (Marks, Aaron)
September 18, 2014 Opinion or Order Filing 49 MEMORANDUM OF LAW in Support re: #46 MOTION to Intervene . and Opposition to 28 U.S.C. 1782 Application and to Quash Subpoena. Document filed by Nygard Inc., Nygard International Inc., Nygard International Partnership. (Marks, Aaron)
September 18, 2014 Opinion or Order Filing 48 DECLARATION of Daane Clifford in Support re: #46 MOTION to Intervene .. Document filed by Nygard Inc., Nygard International Inc., Nygard International Partnership. (Marks, Aaron)
September 18, 2014 Opinion or Order Filing 47 DECLARATION of Aaron H. Marks in Support re: #46 MOTION to Intervene .. Document filed by Nygard Inc., Nygard International Inc., Nygard International Partnership. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D)(Marks, Aaron)
September 18, 2014 Opinion or Order Filing 46 MOTION to Intervene . Document filed by Nygard Inc., Nygard International Inc., Nygard International Partnership.(Marks, Aaron)
September 18, 2014 Opinion or Order Filing 45 NOTICE OF APPEARANCE by Kenneth R. David on behalf of Nygard Inc., Nygard International Inc., Nygard International Partnership. (David, Kenneth)
September 18, 2014 Opinion or Order Filing 44 NOTICE OF APPEARANCE by Aaron Harvey Marks on behalf of Nygard Inc., Nygard International Inc., Nygard International Partnership. (Marks, Aaron)
September 18, 2014 Opinion or Order Filing 43 NOTICE OF APPEARANCE by Marc E. Kasowitz on behalf of Nygard Inc., Nygard International Inc., Nygard International Partnership. (Kasowitz, Marc)
September 18, 2014 Opinion or Order Filing 42 LETTER addressed to Judge Denise L. Cote from Marc E. Kasowitz dated 9/18/2014 re: informing the court of the petitioner's violation of Your Honor's directive at the 9/11/2014 conference. Document filed by Nygard Inc., Nygard International Inc., Nygard International Partnership. (Attachments: #1 Exhibit A)(Kasowitz, Marc)
September 18, 2014 Opinion or Order Filing 41 LETTER addressed to Judge Denise L. Cote from Orin Snyder dated September 18, 2014 re: recent events in California Superior Court. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G)(Snyder, Orin)
September 18, 2014 Opinion or Order Filing 40 LETTER addressed to Judge Denise L. Cote from Steven D. Feldman dated 9/18/14 re: weekly report on production. Document filed by Stephen J. Feralio.(Feldman, Steven)
September 18, 2014 Opinion or Order Filing 39 NOTICE OF APPEARANCE by Sharon Anne O'Shaughnessy on behalf of Stephen J. Feralio. (O'Shaughnessy, Sharon)
September 18, 2014 Opinion or Order Filing 38 NOTICE OF APPEARANCE by Steven David Feldman on behalf of Stephen J. Feralio. (Feldman, Steven)
September 17, 2014 Opinion or Order Filing 37 ENDORSED LETTER addressed to Judge Denise L. Cote from Marc E. Kasowitz dated September 16, 2014 re: Requesting permission to submit a letter under seal pursuant to Rule 4(A) of Your Honor's Individual Practices in Civil Cases. ENDORSEMENT: Having reviewed the parties' submission of Sept. 16, redaction is approved where the parties have agreed, and denied where they have not. The parties shall prepare an order to strike from the docket the relevant submissions to to refile properly redacted documents. They shall provide unredacted pages tot he Court for filing under seal. (Signed by Judge Denise L. Cote on 9/16/2014) (gr)
September 16, 2014 Opinion or Order Filing 36 LETTER addressed to Judge Denise L. Cote from Orin Snyder dated September 16, 2014 re: redactions. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings.(Snyder, Orin)
September 16, 2014 Opinion or Order Filing 35 LETTER addressed to Judge Denise L. Cote from Marc E. Kasowitz dated September 16, 2014 re: Requesting permission to submit a letter under seal pursuant to Rule 4(A) of Your Honor's Individual Practices in Civil Cases. Document filed by Nygard Inc., Nygard International Inc., Nygard International Partnership.(Kasowitz, Marc)
September 15, 2014 Opinion or Order Filing 34 ENDORSED LETTER addressed to Judge Denise L. Cote from Avi Weitzman dated September 12, 2014 re: status of the action. ENDORSEMENT: Granted, nunc pro tunc. (Signed by Judge Denise L. Cote on 9/15/2014) (gr)
September 12, 2014 Opinion or Order Filing 33 LETTER addressed to Judge Denise L. Cote from Avi Weitzman dated September 12, 2014 re: status of the action. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings.(Weitzman, Avi)
September 11, 2014 Opinion or Order Filing 32 SCHEDULING ORDER: The schedule and requirements set out herein are adopted (Signed by Judge Denise Cote on 9/11/14) (sr)
September 11, 2014 Opinion or Order Minute Entry for proceedings held before Judge Denise L. Cote: Conference held on 9/11/2014. (Court Reporter Ann Hairston) (gr)
September 10, 2014 Opinion or Order Filing 31 LETTER addressed to Judge Denise L. Cote from Avi Weitzman dated 9/10/2014 re: request to submit a letter under seal. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings.(Weitzman, Avi)
September 10, 2014 Opinion or Order Filing 30 LETTER addressed to Judge Denise L. Cote from Marc E. Kasowitz dated 9/10/2014 re: Requesting permission to submit a letter under seal pursuant to Rule 4(A) of Your Honor's Individual Practices in Civil Cases. Document filed by Nygard Inc., Nygard International Partnership.(Kasowitz, Marc)
September 8, 2014 Opinion or Order Filing 29 ORDER: A conference in the above-captioned matter is scheduled for September 11, 2014 at 10 a.m. in Courtroom 15B, 500 Pearl Street. (Signed by Judge Denise L. Cote on 9/8/2014) (gr)
September 8, 2014 Opinion or Order NOTICE OF CASE ASSIGNMENT to Judge Denise L. Cote. Judge Part One is no longer assigned to the case. (pgu)
September 5, 2014 Opinion or Order Filing 28 LETTER MOTION for Extension of Time to File Response/Reply to the Application addressed to Judge Ronnie Abrams from Marc E. Kasowitz dated September 5, 2014. Document filed by Nygard Inc., Nygard International Partnership. (Attachments: #1 Extension Request)(Kasowitz, Marc)
September 5, 2014 Opinion or Order Filing 27 LETTER MOTION for Extension of Time to File Response/Reply as to #26 LETTER MOTION for Extension of Time to File Response/Reply as to #1 MOTION Ex Parte Application for the Issuance of Subpoenas Duce Tecum and AD TESTIFICANDUM pursuant to 28 U.S.C. 1782 to Conduct Discovery for use in Foreign Proceedings., #25 and for an extension of the remaining dates set forth in the Order to Show Cause (CORRECTED) addressed to Judge Denise L. Cote from Marc E. Kasowitz dated September 5, 2014. Document filed by Nygard International Partnership, Nygard Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B)(Kasowitz, Marc)
September 5, 2014 Opinion or Order Filing 26 LETTER MOTION for Extension of Time to File Response/Reply as to #1 MOTION Ex Parte Application for the Issuance of Subpoenas Duce Tecum and AD TESTIFICANDUM pursuant to 28 U.S.C. 1782 to Conduct Discovery for use in Foreign Proceedings., #25 LETTER MOTION for Extension of Time to File Response/Reply as to #1 MOTION Ex Parte Application for the Issuance of Subpoenas Duce Tecum and AD TESTIFICANDUM pursuant to 28 U.S.C. 1782 to Conduct Discovery for use in Foreign Proceedings., #9 , #9 Order to Show Cause,,,,,, and for an extension of the remaining dates set forth in the Order to Show Cause (copy with exhibits) addressed to Judge Denise L. Cote from Marc E. Kasowitz dated September 5, 2014. Document filed by Nygard International Inc., Nygard International Partnership. (Attachments: #1 Exhibit A, #2 Exhibit B)(Kasowitz, Marc)
September 5, 2014 Opinion or Order Filing 25 LETTER MOTION for Extension of Time to File Response/Reply as to #1 MOTION Ex Parte Application for the Issuance of Subpoenas Duce Tecum and AD TESTIFICANDUM pursuant to 28 U.S.C. 1782 to Conduct Discovery for use in Foreign Proceedings., #9 Order to Show Cause,,,,,, and for an extension of the remaining dates set forth in the Order to Show Cause addressed to Judge Denise L. Cote from Marc E. Kasowitz dated September 5, 2014. Document filed by Nygard International Partnership, Nygard International Inc..(Kasowitz, Marc)
August 29, 2014 Opinion or Order Filing 24 NOTICE OF APPEARANCE by Avi Weitzman on behalf of The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Weitzman, Avi)
August 20, 2014 Opinion or Order Filing 23 CERTIFICATE OF SERVICE of Initial Pleadings listed in Certificate of Service served on Rt. Hon Perry G. Christie, Prime Minister of the Commonwealth of the Bahamas; Hon. Philip E. Brave Davis, Deputy Minister of the Commonwealth of the Bahamas; Hon. Glenys Hanna-Martin, Minister of Transport and Aviation of the Commonwealth of the Bahamas; The Town Planning Committee; Hon. Kenred Dorsett, Minister of Environment and Housing; and Craig G. Delancy, Buildings Control Officer on 08/19/2014. Service was accepted by Karen Dorsett. Service was made by electronic mail. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Certificate of Service)(Snyder, Orin)
August 20, 2014 Opinion or Order Filing 22 AFFIDAVIT OF SERVICE of Initial Pleadings listed in Certificate of Service served on Nygard International Partnership on 08/15/2014 and 08/19/2014. Service was accepted by Leo Evans, Manager. Service was made by electronic mail. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Certificate of Service)(Snyder, Orin)
August 20, 2014 Opinion or Order Filing 21 CERTIFICATE OF SERVICE of Initial Pleadings listed in Certificate of Service served on Peter Nygard on 08/19/2014 and 08/20/2014. Service was accepted by Annette Neely and Dashanique Poiter. Service was made by electronic mail. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Certificate of Service)(Snyder, Orin)
August 20, 2014 Opinion or Order Filing 20 CERTIFICATE OF SERVICE of Initial Pleadings listed in Certificate of Service served on Wendall Jones on 08/19/2014 and 08/20/2014. Service was accepted by Lenor Thompson, Receptionist. Service was made by electronic mail. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Affidavit of Service)(Snyder, Orin)
August 20, 2014 Opinion or Order Filing 19 CERTIFICATE OF SERVICE of Initial Pleadings listed in Certificate of Service served on Jones Communications Network on 08/19/2014 and 08/20/2014. Service was accepted by Lenor Thompson, Receptionist. Service was made by electronic mail. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Affidavit of Service)(Snyder, Orin)
August 20, 2014 Opinion or Order Filing 18 CERTIFICATE OF SERVICE of Initial Pleadings listed in Certificate of Service served on Sherman Brown on 08/19/2014. Service was accepted by Arianne Cartwright, Receptionist. Service was made by electronic mail. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D)(Snyder, Orin)
August 20, 2014 Opinion or Order Filing 17 CERTIFICATE OF SERVICE of Initial Pleadings listed in Certificate of Service served on Phillipa Russell on 08/19/2014. Service was accepted by Thomas H. Evans, Senior Partner. Service was made by electronic mail. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D)(Snyder, Orin)
August 20, 2014 Opinion or Order Filing 16 CERTIFICATE OF SERVICE of Initial Pleadings listed in Certificate of Service served on Keod Smith on 08/19/2014 and 08/20/2014. Service was accepted by Italia Balfour. Service was made by electronic mail. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Certificate of Service - Electronic Mailing)(Snyder, Orin)
August 20, 2014 Opinion or Order Filing 15 CERTIFICATE OF SERVICE of Initial Pleadings listed in Certificate of Service served on Earlin Williams on 08/19/2014. Service was accepted by Arianne Cartwright, Receptionist. Service was made by electronic mail. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D)(Snyder, Orin)
August 20, 2014 Opinion or Order Filing 14 CERTIFICATE OF SERVICE of Initial Pleadings listed in Certificate of Service served on Carvel Francis on 08/13/2014 and 08/19/2014. Service was accepted by Shawna Rahming, Receptionist. Service was made by electronic mail. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D)(Snyder, Orin)
August 14, 2014 Opinion or Order Filing 13 DECLARATION of JENNY AFIA in Support re: 3 Declaration in Support,. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Exhibit 91 to 100, #2 Exhibit 101 to 110, #3 Exhibit 111 to 119, #4 Exhibit 120, #5 Exhibit 121, #6 Exhibit 122, #7 Exhibit 123, #8 Exhibit 124, #9 Exhibit 125, #10 Exhibit 126, #11 Exhibit 127, #12 Exhibit 128, #13 Exhibit 129, #14 Exhibit 130, #15 Exhibit 131, #16 Exhibit 132, #17 Exhibit 133, #18 Exhibit 134)(Snyder, Orin)
August 14, 2014 Opinion or Order Filing 12 DECLARATION of JENNY AFIA in Support re: 3 Declaration in Support,. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Exhibit 56, #2 Exhibit 57, #3 Exhibit 58, #4 Exhibit 59, #5 Exhibit 60, #6 Exhibit 61, #7 Exhibit 62, #8 Exhibit 63, #9 Exhibit 64, #10 Exhibit 65, #11 Exhibit 66, #12 Exhibit 67 to 80, #13 Exhibit 81, #14 Exhibit 82, #15 Exhibit 83, #16 Exhibit 84, #17 Exhibit 85, #18 Exhibit 86, #19 Exhibit 87, #20 Exhibit 88, #21 Exhibit 89, #22 Exhibit 90)(Snyder, Orin)
August 14, 2014 Opinion or Order Filing 11 DECLARATION of JENNY AFIA in Support re: 3 Declaration in Support,. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: #1 Exhibit 1 to 10, #2 Exhibit 11 to 20, #3 Exhibit 21 to 30, #4 Exhibit 31 to 35, #5 Exhibit 36, #6 Exhibit 37, #7 Exhibit 38, #8 Exhibit 39, #9 Exhibit 40, #10 Exhibit 41, #11 Exhibit 42, #12 Exhibit 43, #13 Exhibit 44, #14 Exhibit 45, #15 Exhibit 46, Part 1, #16 Exhibit 46, Part 2, #17 Exhibit 46, Part 3, #18 Exhibit 47 to 55)(Snyder, Orin)
August 13, 2014 Opinion or Order ***STRICKEN DOCUMENT. Deleted document number 2 from the case record. The document was stricken from this case pursuant to #77 Order. (ajs)
August 13, 2014 Opinion or Order ***STRICKEN DOCUMENT. Deleted document number 4 from the case record. The document was stricken from this case pursuant to #77 Order. (ajs)
August 13, 2014 Opinion or Order ***STRICKEN DOCUMENT. Deleted document number 3 from the case record. The document was stricken from this case pursuant to #77 Order. (ajs)
August 13, 2014 Opinion or Order ***STRICKEN DOCUMENT. Deleted document number 5 from the case record. The document was stricken from this case pursuant to #77 Order. (ajs)
August 13, 2014 Opinion or Order Filing 10 STIPULATION AND ORDER: IT IS HEREBY STIPULATED AND AGREED, by and between Petitioners and the Respondent, through their respective undersigned counsel, the following: 1. Petitioners may serve Respondent with the Subpoena in the Southern District of New York though Respondent's counsel and as further set forth in this order. (Signed by Judge Ronnie Abrams on 8/13/2014) (lmb)
August 13, 2014 Opinion or Order Filing 9 ORDER TO SHOW CAUSE WHY THE COALITION TO PROTECT CLIFTON BAY AND LOUIS BACON SHOULD NOT BE GRANTED LEAVE TO CONDUCT DISCOVERY FOR USE IN FOREIGN PROCEEDINGS: It is hereby ORDERED that Petitioners shall serve copies of this Order, the Stipulation, this Application, the Memorandum of Law, the supporting declarations (with exhibits attached thereto), and any other materials submitted in connection with this Application on counsel for the defendants in the Bahamian judicial actions for which this Application seeks discovery, as well as on Nygard International, by hand with copy by e-mail, no later than 5:00 p.m. on August 20, 2014; and ORDERED that papers in opposition to the Application, if any, shall be served by hand, facsimile, or e-mail upon Petitioners' counsel, Gibson Dunn & Crutcher, LLP, 200 Park Avenue, 47th Floor, New York New York, on or before 5:00 p.m. on September 10, 2010; and ORDERED that a reply memorandum in support of the Application, if any, shall be served by hand, facsimile, or e-mail upon counsel for any party submitting opposing papers on or before 5:00 p.m. on September 19, 2014; and ORDERED that Petitioners, Respondent, and any other individual or entity that has filed papers in opposition to the Application show cause before Judge Oetken, who will then be presiding in Part I at a hearing on October 7, at 12:00 p.m., or as soon thereafter as counsel may be heard, why Petitioners should not be granted leave to obtain the requested discovery from Respondent for use in foreign proceedings. Show Cause Hearing set for 10/7/2014 at 12:00 PM before Part One Judge. (Signed by Judge Ronnie Abrams on 8/13/2014) (lmb) Modified on 8/15/2014 (lmb).
August 13, 2014 Opinion or Order Filing 8 NOTICE of THE COALITION TO PROTECT CLIFTON BAY AND LOUIS BACON'S APPLICATION AND PETITION FOR ORDER PURSUANT TO 28 U.S.C. 1782 TO CONDUCT DISCOVERY FOR USE IN FOREIGN PROCEEDINGS re: #1 MOTION Ex Parte Application for the Issuance of Subpoenas Duce Tecum and AD TESTIFICANDUM pursuant to 28 U.S.C. 1782 to Conduct Discovery for use in Foreign Proceedings.. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Snyder, Orin)
August 13, 2014 Opinion or Order Filing 7 DECLARATION of ORIN SNYDER in Support re: #1 MOTION Ex Parte Application for the Issuance of Subpoenas Duce Tecum and AD TESTIFICANDUM pursuant to 28 U.S.C. 1782 to Conduct Discovery for use in Foreign Proceedings.. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Snyder, Orin)
August 13, 2014 Opinion or Order Filing 6 DECLARATION of LOUIS M. BACON in Support re: #1 MOTION Ex Parte Application for the Issuance of Subpoenas Duce Tecum and AD TESTIFICANDUM pursuant to 28 U.S.C. 1782 to Conduct Discovery for use in Foreign Proceedings.. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Snyder, Orin)
August 13, 2014 Opinion or Order Filing 5 DECLARATION of JACK PALLADINO in Support re: #1 MOTION Ex Parte Application for the Issuance of Subpoenas Duce Tecum and AD TESTIFICANDUM pursuant to 28 U.S.C. 1782 to Conduct Discovery for use in Foreign Proceedings.. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5)(Snyder, Orin)
August 13, 2014 Opinion or Order Filing 4 DECLARATION of STEVEN J. FERALIO in Support re: #1 MOTION Ex Parte Application for the Issuance of Subpoenas Duce Tecum and AD TESTIFICANDUM pursuant to 28 U.S.C. 1782 to Conduct Discovery for use in Foreign Proceedings.. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Attachments: # 1 Exhibit 1)(Snyder, Orin)
August 13, 2014 Opinion or Order Filing 3 DECLARATION of JENNY AFIA in Support re: #1 MOTION Ex Parte Application for the Issuance of Subpoenas Duce Tecum and AD TESTIFICANDUM pursuant to 28 U.S.C. 1782 to Conduct Discovery for use in Foreign Proceedings.. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Snyder, Orin)
August 13, 2014 Opinion or Order Filing 2 MEMORANDUM OF LAW in Support re: #1 MOTION Ex Parte Application for the Issuance of Subpoenas Duce Tecum and AD TESTIFICANDUM pursuant to 28 U.S.C. 1782 to Conduct Discovery for use in Foreign Proceedings. . Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings. (Snyder, Orin)
August 13, 2014 Opinion or Order Filing 1 Application and Petition for an Order pursuant to 28 U.S.C. 1782 to Conduct Discovery for use in Foreign Proceedings. Document filed by The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings.(wb) (sdi).

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In re: The Coalition to Protect Clifton Bay and Louis Bacon for an Order Pursuant to 28 U.S.C. 1782 to Conduct Discovery in foreign Proceedings
Represented By: Avi Weitzman
Represented By: Orin Snyder
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Petitioner: Louis Bacon
Represented By: Jacob W Buchdahl
Represented By: Mark P. Musico
Represented By: Stephen Shackelford, Jr.
Represented By: William Christopher Carmody
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Respondent: Stephen J. Feralio
Represented By: Sharon Anne O'Shaughnessy
Represented By: Steven David Feldman
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Interested party: Nygard International Partnership
Represented By: Marc E. Kasowitz
Represented By: Aaron Harvey Marks
Represented By: Kenneth R. David
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Interested party: Nygard International Inc.
Represented By: Aaron Harvey Marks
Represented By: Marc E. Kasowitz
Represented By: Kenneth R. David
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Interested party: Nygard Inc.
Represented By: Marc E. Kasowitz
Represented By: Aaron Harvey Marks
Represented By: Kenneth R. David
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