Citigroup Inc. v. Seade
Petitioner: Citigroup Inc.
Respondent: Luis Sebastian Sayeg Seade
Case Number: 1:2021cv10413
Filed: December 6, 2021
Court: US District Court for the Southern District of New York
Presiding Judge: John P Cronan
Nature of Suit: Other Statutes: Arbitration
Cause of Action: 09 U.S.C. ยง 303
Jury Demanded By: None
Docket Report

This docket was last retrieved on April 4, 2022. A more recent docket listing may be available from PACER.

Date Filed Document Text
January 25, 2022 Opinion or Order Filing 37 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERENCE proceeding held on 1/20/22 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....(Moya, Goretti)
January 25, 2022 Opinion or Order Filing 36 TRANSCRIPT of Proceedings re: CONFERENCE held on 1/20/2022 before Judge John P. Cronan. Court Reporter/Transcriber: Khristine Sellin, (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 2/15/2022. Redacted Transcript Deadline set for 2/25/2022. Release of Transcript Restriction set for 4/25/2022..(Moya, Goretti)
January 21, 2022 Opinion or Order Filing 35 DECLARATION of Ryan R. Adelsperger re: #33 Memorandum & Opinion,, #34 Preliminary Injunction,,,,,,, /Declaration of Service of Ryan R. Adelsperger. Document filed by Citigroup Inc...(Adelsperger, Ryan)
January 20, 2022 Opinion or Order Minute Entry for proceedings held before Judge John P. Cronan: Telephone Conference held on January 20, 2022. The Court held the scheduled hearing to discuss the petition to compel arbitration and whether the Court should continue and expand the Preliminary Injunction. Petitioner Citigroup Inc. appeared but Respondent Luis Sebastian Sayeg Seade did not appear. The Court noted that it would issue a separate opinion and order addressing the petition to compel arbitration and whether it will continue and expand the Preliminary Injunction. (Court Reporter Khris Sellin) (mhe)
January 20, 2022 Opinion or Order Filing 34 AMENDED PRELIMINARY INJUNCTION ORDER: Pending the completion of the arbitration now pending before the American Arbitration Association ("AAA") in New York entitled, Citigroup Inc. v. Luis Sebastin Sayeg Seade, AAA Case No. 01-21-0017-7441 (the "Arbitration"), the Court orders as follows: (a) Until the conclusion of the Arbitration, Sayeg is enjoined and restrained, together with Sayegs officers, agents, servants, employees, and attorneys, and all other persons who are in active concert or participation with Sayeg or any of his officers, agents, servants, employees, or attorneys, from commencing or prosecuting any action or proceeding, in Mexico or elsewhere, arising out of or related to: Citigroup's Discretionary Incentive and Retention Award Plan, as amended and restated effective as of January 1, 2015 and Citigroup's Capital Accumulation Program and Deferred Cash Award Plan each awarded to Sayeg on February 14, 2019 and February 15, 2018 (collectively, the "Plans") other than in the Arbitration;(b) Sayeg is directed by February 3, 2022, to dismiss without prejudice claims arising out of or related to the applicability or not applicability of benefits under the Plans in the proceeding captioned as Luis Sebastian Sayeg Seade v. Banco Nacional de Mexico, S.A., Integrante del Grupo Financiero Banamex, Expediente Numero: 1197/2020; and (c) Sayeg is compelled to arbitrate any dispute between the parties arising out of or related to the applicability or not applicability of benefits under the Plans in the Arbitration. Citigroup shall immediately serve a copy of this Order on Sayeg, with proof of service filed on the docket no later than January 21, 2022. SO ORDERED. (Signed by Judge John P. Cronan on 1/20/2022) (jca) Modified on 1/26/2022 (jca).
January 20, 2022 Opinion or Order Filing 33 OPINION AND ORDER: For reasons discussed above, the Court compels arbitration and orders Sayeg to participate in the Arbitration. As also ordered above, and will be detailed in a separate Order, Sayeg must cease prosecuting and must withdraw any claims in the Mexican Action arising out of or related to the Plans by February 3, 2022. Citigroup shall file a letter by February 10, 2022, updating the Court on whether Sayeg has withdrawn the required claims from the Mexican Action. Citigroup shall immediately serve a copy of this Order on Sayeg, with proof of service filed on the docket no later than January 21, 2022. SO ORDERED. (Signed by Judge John P. Cronan on 1/20/2022) (jca)
January 14, 2022 Opinion or Order Filing 32 LETTER addressed to Judge John P. Cronan from Robert L. Sills dated January 14, 2022 re: service of order dated January 11, 2022 (Dkt. 30). Document filed by Citigroup Inc...(Sills, Robert)
January 14, 2022 Opinion or Order Filing 31 DECLARATION of Ryan R. Adelsperger re: #30 Order,,,, Set Deadlines/Hearings,,, . Document filed by Citigroup Inc...(Adelsperger, Ryan)
January 11, 2022 Opinion or Order Filing 30 ORDER: The parties shall appear for a teleconference on January 20, 2022, at 11:00 a.m. At the scheduled time, counsel for all parties should call (866) 434-5269, access code 9176261. The parties should be prepared to discuss at the teleconference the petition to compel arbitration and whether the Court should continue and expand the Preliminary Injunction. Some of the issues thatthe parties should be prepared to discuss include: As set forth herein. Citigroup shall immediately serve a copy of this Order on Sayeg, with proof of service filed on the docket no later than January 13, 2022. SO ORDERED., ( Telephone Conference set for 1/20/2022 at 11:00 AM before Judge John P. Cronan.) (Signed by Judge John P. Cronan on 1/11/2022) (ama)
January 3, 2022 Opinion or Order Filing 29 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERENCE proceeding held on 12/22/21 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....(Moya, Goretti)
January 3, 2022 Opinion or Order Filing 28 TRANSCRIPT of Proceedings re: CONFERENCE held on 12/22/2021 before Judge John P. Cronan. Court Reporter/Transcriber: Paula Speer, (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 1/24/2022. Redacted Transcript Deadline set for 2/3/2022. Release of Transcript Restriction set for 4/4/2022..(Moya, Goretti)
December 29, 2021 Opinion or Order Filing 27 MEMO ENDORSEMENT on re: #26 Letter filed by Citigroup Inc. ENDORSEMENT: The Court denies Citigroup's request to amend the preliminary injunction without prejudice. As noted, the preliminary injunction has been ordered to continue until the conclusion of the arbitration, or until this Court decides the petition to compel arbitration, whichever is earlier. When the Court resolves the petition to compel, the Court will consider whether to extend the preliminary injunction and, if so, whether to order any modifications to the injunction, including Citigroup's request to require Sayeg to dismiss any proceedings in Mexico that fall within the scope of the injunction. SO ORDERED. (Signed by Judge John P. Cronan on 12/29/2021) (vfr)
December 28, 2021 Opinion or Order Filing 26 LETTER addressed to Judge John P. Cronan from Robert L. Sills dated December 28, 2021 re: typographical or clerical error in the Order, Dkt no. 22. Document filed by Citigroup Inc...(Sills, Robert)
December 27, 2021 Opinion or Order Filing 25 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERENCE proceeding held on 12/17/21 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....(Moya, Goretti)
December 27, 2021 Opinion or Order Filing 24 TRANSCRIPT of Proceedings re: CONFERENCE held on 12/17/2021 before Judge John P. Cronan. Court Reporter/Transcriber: Michael McDaniel, (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 1/18/2022. Redacted Transcript Deadline set for 1/27/2022. Release of Transcript Restriction set for 3/28/2022..(Moya, Goretti)
December 22, 2021 Opinion or Order Filing 23 DECLARATION of Ryan R. Adelsperger re: #22 Order,,,,,,,, Set Deadlines,,,,,,, . Document filed by Citigroup Inc...(Adelsperger, Ryan)
December 22, 2021 Opinion or Order Filing 22 ORDER: For the reasons stated on the record, the Court, under Federal Rule of Civil Procedure 65(a), enters a Preliminary Injunction enjoining and restraining Sayeg, together with his officers, agents, servants, employees, and attorneys, and all other persons who are in active concert or participation with Sayeg or any of his officers, agents, servants, employees, or attorneys, from commencing or prosecuting any action or proceeding, in Mexico or elsewhere, arising out of or related to Citigroup's Discretionary Incentive and Retention Award Plan, as amended and restated effective as of January 1, 2015 and Citigroup's Capital Accumulation Program and Deferred Cash Award Plan each awarded to Sayeg on February 14, 2019 and February 15, 2018 (collectively, the "Plans") other than in the arbitration now pending in New York entitled Citigroup Inc. v. Luis Sebastin Sayeg Seade, AAA Case No. 01-21-0017-7441. As such, Sayeg is directed to immediately cease the prosecution of any such proceeding in Mexico or elsewhere. The preliminary injunction shall continue until the conclusion of the above arbitration, or until this Court decides the petition to compel arbitration, whichever is earlier. Sayeg shall also file any opposition to the petition to compel arbitration, see Dkt. 10, by January 5, 2022. If the Court does not receive any opposition by January 5, the petition to compel arbitration will be considered unopposed. Any reply brief is due by January 12, 2022. Citigroup shall immediately serve a copy of this Order on Sayeg, with proof of service filed on the docket no later than December 23, 2021. SO ORDERED. (Responses due by 1/5/2022, Replies due by 1/12/2022.) (Signed by Judge John P. Cronan on 12/22/2021) (jca)
December 22, 2021 Opinion or Order Minute Entry for proceedings held before Judge John P. Cronan: Preliminary injunction hearing held on December 22, 2021. Petitioner Citigroup Inc. appeared but Respondent Luis Sebastian Sayeg Seade did not appear. For the reasons given on the record, the Court granted the preliminary injunction against Respondent, which the Court will enter by separate order. The Court also ordered Respondent to file any opposition to the petition to compel arbitration by January 5, 2022. (Court Reporter Paula Speer). (mhe)
December 17, 2021 Opinion or Order Minute Entry for proceedings held before Judge John P. Cronan: Conference held on December 17, 2021. The Court held the scheduled conference to discuss Petitioner Citigroup Inc.s application for a temporary restraining order. Petitioner appeared but Respondent Luis Sebastian Sayeg Seade did not appear. For the reasons given on the record, the Court granted the TRO application and will enter the TRO by separate order. The Court also ordered Sayeg to appear via teleconference on December 22, 2021, at 10:00 a.m. to show cause why a preliminary injunction should not be entered. At the scheduled time, counsel for all parties should call (866) 434-5269, access code 9176261. (Court Reporter Michael McDaniel). (mhe)
December 17, 2021 Opinion or Order Filing 21 DECLARATION of Ryan R. Adelsperger re: #20 Order to Show Cause,,,,,,,,,,,,,, Set Hearings,,,,,,,,,,,,, . Document filed by Citigroup Inc...(Adelsperger, Ryan)
December 17, 2021 Opinion or Order Filing 20 ORDER TO SHOW CAUSE AND TEMPORARY RESTRAINING ORDER: It is hereby: ORDERED that the above named respondent, Luis Sebastin Sayeg Seade, SHOW CAUSE before this Court on December 22, 2021 at 10 o'clock a.m., or as soon thereafter as counsel may be heard, via a teleconference (at the scheduled time, counsel for all parties should call (866) 434-5269, access code 9176261). IT IS FURTHER ORDERED that, pending the hearing of petitioner's application for a preliminary injunction, Sayeg, together with his agents, servants, employees, and attorneys, and all other persons who are in active concert or participation with Sayeg or any of his agents, servants, employees, or attorneys, pursuant to Rule 65(b) of the Federal Rules of Civil Procedure, are temporarily RESTRAINED AND ENJOINED from commencing or further prosecuting any action or proceeding, in Mexico or elsewhere, against Citigroup, arising out of or relating to the Plans, other than in the Arbitration; IT IS FURTHER ORDERED that papers in opposition to petitioner's application for a preliminary injunction be served on petitioners counsel (by ECF or otherwise) so as to be received by them on or before 5:00 p.m. Eastern Standard Time on December 20, 2021 and that reply papers in further support of petitioners application be served on respondent's counsel so as to be received by them (by ECF or otherwise) on or before 5:00 p.m. on December 21, 2021. IT IS FURTHER ORDERED that service by email, on or before 7:00p.m. on December 17, 2021 of this Order, together with a copy of the papers on which it is based, and together with the summons and complaint herein, on Sayeg and on the attorneys representing him in Mexico, Cavazos Flores, S.C., at (a) their email address, omar130533@yahoo.com.mx, and (b) upon his and their addresses by Federal Express or other courier service at Avenida Arteaga y Salazar 823, Casa 11, Colonia el Contadero, Cuajimalpa de Morelos, Mexico City, Mexico 05500 and Calle Anaxgoras nmero 733, Interior 6, Colonia Narvarte, Alcalda Benito Jurez, Mexico City, Mexico 03020, shall constitute good and sufficient service for all purposes of this (a) Order, (b) the papers upon which it is based, and (c) the summons and petition herein for all purposes, pursuant to Rule 4(f) of the Federal Rules of Civil Procedure; and IT IS FURTHER ORDERED that the foregoing is granted without security. As discussed on the record at the December 17, 2021 hearing on Petitioner's application for a temporary restraining order ("TRO"), Respondent had ten days' notice of that hearing yet failed to appear; has been served with the summons and petition, as well as briefing by Petitioner in support of its request for injunctive relief; and did not file a brief in connection with the TRO application by the December 15, 2021 deadline set by the Court to do so. Given Respondent's notice of Petitioners application for injunctive relief, the pending action in Mexico, and the importance of a prompt determination of any arbitration rights, the Court schedules the preliminary injunction hearing for December 22, 2021, at 10 a.m. If Respondent believes that this scheduled time provides him with insufficient time to oppose the preliminary injunction, he may request an adjournment of that hearing date. SO ORDERED. (Telephone Conference set for 12/22/2021 at 10:00 AM before Judge John P. Cronan.) (Signed by Judge John P. Cronan on 12/17/2021) (jca)
December 10, 2021 Opinion or Order Filing 19 DECLARATION of Oscar De La Vega Gomez re: #12 Order, Set Deadlines, Set Hearings,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, /SUPPLEMENTAL DECLARATION OF OSCAR DE LA VEGA GOMEZ IN SUPPORT OF PETITIONER'S SUPPLEMENTAL MEMORANDUM. Document filed by Citigroup Inc.. (Attachments: #1 Exhibit 1-Mexican Constitution, #2 Exhibit 2-Article 604 of the Mexican Federal Labor Law, #3 Exhibit 3-Francisco Gonzlez de Cosso, #4 Exhibit 4-Gonzalo Uribarri Carpintero).(Sills, Robert)
December 10, 2021 Opinion or Order Filing 18 SUPPLEMENTAL MEMORANDUM OF LAW re: #12 Order, Set Deadlines, Set Hearings,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, /SUPPLEMENTAL MEMORANDUM IN SUPPORT OF PETITIONERS MOTION TO COMPEL ARBITRATION AND FOR AN ANTI-SUIT INJUNCTION. Document filed by Citigroup Inc...(Sills, Robert)
December 8, 2021 Opinion or Order Filing 17 DECLARATION of Ryan R. Adelsperger re: #15 Order on Motion to Adjourn Conference, #12 Order, Set Deadlines, Set Hearings,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, . Document filed by Citigroup Inc...(Adelsperger, Ryan)
December 8, 2021 Opinion or Order Filing 16 NOTICE OF APPEARANCE by Ryan Adelsperger on behalf of Citigroup Inc...(Adelsperger, Ryan)
December 8, 2021 Opinion or Order Filing 15 ORDER granting #14 LETTER MOTION to Adjourn Conference / Teleconference. This request is granted. The conference scheduled for December 17, 2021 at 11:00 a.m. is adjourned to December 17, 2021 at 2:30 p.m. At the scheduled time, counsel for all parties shall call 866-434-5269, access code 9176261. SO ORDERED. Telephone Conference set for 12/17/2021 at 02:30 PM before Judge John P. Cronan.. (Signed by Judge John P. Cronan on 12/8/2021) (jca)
December 7, 2021 Opinion or Order Filing 14 LETTER MOTION to Adjourn Conference / Teleconference addressed to Judge John P. Cronan from Robert L. Sills dated December 7, 2021. Document filed by Citigroup Inc...(Sills, Robert)
December 7, 2021 Opinion or Order Filing 13 ELECTRONIC SUMMONS ISSUED as to Luis Sebastian Sayeg Seade. (vf)
December 7, 2021 Opinion or Order Filing 12 ORDER: By December 10, 2021, Citigroup shall file a supplemental brief further detailing why the Court should issue a TRO. The brief shall address: 1. Whether Citigroup meets the standards for a TRO, including irreparable harm, given the delay between when Sayeg brought the Mexico action and when Citigroup filed this lawsuit. 2. How China Trade & Development Corp. v. M.V. Choong Yong, 837 F.2d 33 (2d Cir. 1987), and its progeny apply to first-filed foreign actions. See ED Cap., LLC v. Bloomfield Inv. Res. Corp., 155 F. Supp. 3d 434, 442-43 (S.D.N.Y. 2016) ("Much of the analysis in China Trade examining whether a foreign suit is vexatious or threatens the United States court's jurisdiction is strained in a case where the foreign action was filed first."), aff'd in part on other grounds, vacated in part on other grounds, 660 F. App'x 27 (2d Cir. 2016). Citigroup shall point to other cases in which a court has issued an anti-suit injunction for first-filed foreign actions. See id. at 443 ("[The plaintiff] does not cite any case in which an anti-suit injunction was granted by a United States court against a first-filed foreign action."); Robinson v. Jardine Ins. Brokers Intern. Ltd., 856 F. Supp. 554, 560 n.23 (N.D. Cal. 1994) ("Plaintiff has not pointed to any precedent for a federal district court enjoining an earlier-filed foreign proceeding."). 3. Whether the first-to-file rule applies to first-filed foreign suits and, if so, how the rule applies in that context. Under this principle, "the basic proposition [is] that the first court to obtain jurisdiction of the parties and of the issues should have priority over a second court to do so." AEP Energy Servs. Gas Holding Co. v. Bank of Am., N.A., 626 F.3d 699, 722 (2d Cir. 2010) (quotations omitted). The submission should also address whether Mexico's treaty obligations to recognize arbitration agreements affects the special circumstances analysis for the first-to-file rule. See id. 4. How the Colorado River doctrine and international comity principles apply to a first-filed foreign suit with a nearly identical pending motion to the relief sought in a latter filed federal case. See, e.g., Royal & Sun All. Ins. Co. of Canada v. Century Int'l Arms, Inc., 466 F.3d 88, 92-94 (2d Cir. 2006) (outlining these principles and noting that the Second Circuit has "yet to articulate a list of factors a district court should consider when exercising its discretion to abstain in deference to pending litigation in a foreign court"). 5. Whether Mexican law allows Citigroup to intervene in the Mexican case. Sayeg shall file a response to Citigroup's brief by December 15, 2021. The parties shall appear for a teleconference to discuss the TRO application on December 17, 2021, at 11:00 a.m. At the scheduled time, counsel for all parties should call (866) 434-5269, access code 9176261. If Citigroup desires a more expedited schedule, it may seek leave of the Court. Citigroup shall immediately serve a copy of the summons, the Petition and Complaint, and this Order on Sayeg, with proof of service filed on the docket no later than December 8, 2021. SO ORDERED. ( Responses to Brief due by 12/15/2021, Service due by 12/8/2021.), ( Telephone Conference set for 12/17/2021 at 11:00 AM before Judge John P. Cronan.) (Signed by Judge John P. Cronan on 12/7/2021) (tg)
December 7, 2021 Opinion or Order Filing 11 REQUEST FOR ISSUANCE OF SUMMONS as to Luis Sebastin Sayeg Seade, re: #10 Petition to Compel/Confirm/Modify/Stay/Vacate Arbitration. Document filed by Citigroup Inc...(Sills, Robert)
December 7, 2021 Opinion or Order Filing 10 PETITION TO COMPEL ARBITRATION..Document filed by Citigroup Inc.. (Attachments: #1 Exhibit A Award Agreement).(Sills, Robert)
December 7, 2021 Opinion or Order CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge John P. Cronan. Please download and review the Individual Practices of the assigned District Judge, located at #https://nysd.uscourts.gov/judges/district-judges. Attorneys are responsible for providing courtesy copies to judges where their Individual Practices require such. Please download and review the ECF Rules and Instructions, located at #https://nysd.uscourts.gov/rules/ecf-related-instructions..(jgo)
December 7, 2021 Opinion or Order ***NOTICE TO ATTORNEY REGARDING DEFICIENT PLEADING. Notice to Attorney Robert L. Sills to RE-FILE Document No. #1 Petition to Compel/Confirm/Modify/Stay/Vacate Arbitration,. The filing is deficient for the following reason(s): the PDF attached to the docket entry for the pleading is not correct; the PDF must include the title to correspond with the event type used (Petition to Compel Arbitration). Re-file the pleading using the event type Petition to Compel/Confirm/Modify/Stay/Vacate Arbitration found under the event list Complaints and Other Initiating Documents - attach the correct signed PDF - select the individually named filer/filers - select the individually named party/parties the pleading is against. If the deficiency/deficiencies are not corrected within five (5) days per Amended Standing Order 15-mc-00131 this case will be administratively closed. Initial Pleading due by 12/13/2021. (jgo)
December 7, 2021 Opinion or Order Magistrate Judge Debra C. Freeman is so designated. Pursuant to 28 U.S.C. Section 636(c) and Fed. R. Civ. P. 73(b)(1) parties are notified that they may consent to proceed before a United States Magistrate Judge. Parties who wish to consent may access the necessary form at the following link: #https://nysd.uscourts.gov/sites/default/files/2018-06/AO-3.pdf. (jgo)
December 7, 2021 Opinion or Order Case Designated ECF. (jgo)
December 7, 2021 Opinion or Order ***NOTICE TO ATTORNEY REGARDING DEFICIENT REQUEST FOR ISSUANCE OF SUMMONS. Notice to Attorney Robert L. Sills to RE-FILE Document No. #3 Request for Issuance of Summons,. The filing is deficient for the following reason(s): summons request must be linked to the properly filed pleading. Refile summons request after the pleading has been properly refiled;. Re-file the document using the event type Request for Issuance of Summons found under the event list Service of Process - select the correct filer/filers - and attach the correct summons form PDF. (jgo)
December 7, 2021 Opinion or Order ***NOTICE TO COURT REGARDING PROPOSED ORDER TO SHOW CAUSE WITH EMERGENCY RELIEF. Document No. #5 Proposed Order to Show Cause With Emergency Relief was reviewed and approved as to form. (km)
December 6, 2021 Opinion or Order Filing 9 DECLARATION of Oscar De La Vega Gomez in Support re: #5 Proposed Order to Show Cause With Emergency Relief. Document filed by Citigroup Inc.. (Attachments: #1 Exhibit 1 Termination and Release, #2 Exhibit 2. Mexican Complaint, #3 Exhibit 3 2/26 Mexican Order, #4 Exhibit 4 Amended Mexican Complaint, #5 Exhibit 5 8/27 Hearing Minutes, #6 Exhibit 6 12/1 Hearing Minutes, #7 Exhibit 7 Mexican Answer, #8 Exhibit 8 Jurisdictional Motion).(Sills, Robert)
December 6, 2021 Opinion or Order Filing 8 DECLARATION of Michael A. Sirgado in Support re: #5 Proposed Order to Show Cause With Emergency Relief. Document filed by Citigroup Inc.. (Attachments: #1 Exhibit 1 DIRAP, #2 Exhibit 2 2018 Award Agreement, #3 Exhibit 3 2018 CAP Prospectus, #4 Exhibit 4 2018 DCAP Brochure, #5 Exhibit 5 2019 Award Agreement, #6 Exhibit 6 2019 CAP Prospectus, #7 Exhibit 7 2019 DCAP Brochure, #8 Exhibit 8 2014 Stock Incentive Plan, #9 Exhibit 9 2019 Stock Incentive Plan).(Sills, Robert)
December 6, 2021 Opinion or Order Filing 7 DECLARATION of Robert L. Sills in Support re: #5 Proposed Order to Show Cause With Emergency Relief. Document filed by Citigroup Inc.. (Attachments: #1 Exhibit 1 AAA Demand for Arbitration).(Sills, Robert)
December 6, 2021 Opinion or Order Filing 6 MEMORANDUM OF LAW in Support re: #5 Proposed Order to Show Cause With Emergency Relief . Document filed by Citigroup Inc...(Sills, Robert)
December 6, 2021 Opinion or Order Filing 5 PROPOSED ORDER TO SHOW CAUSE WITH EMERGENCY RELIEF. Document filed by Citigroup Inc...(Sills, Robert) Proposed Order to Show Cause to be reviewed by Clerk's Office staff.
December 6, 2021 Opinion or Order Filing 4 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Citigroup Inc...(Sills, Robert)
December 6, 2021 Opinion or Order Filing 3 FILING ERROR SUMMONS NOT LINKED TO CORRESPONDING PLEADING- REQUEST FOR ISSUANCE OF SUMMONS as to Luis Sebastin Sayeg Seade, re: #1 Petition to Compel/Confirm/Modify/Stay/Vacate Arbitration. Document filed by Citigroup Inc...(Sills, Robert) Modified on 12/7/2021 (jgo).
December 6, 2021 Opinion or Order Filing 2 CIVIL COVER SHEET filed..(Sills, Robert)
December 6, 2021 Opinion or Order Filing 1 FILING ERROR - DEFICIENT PLEADING PDF ERROR - PETITION TO COMPEL ARBITRATION. (Filing Fee $ 402.00, Receipt Number ANYSDC-25430039).Document filed by Citigroup Inc.. (Attachments: #1 Exhibit A Award Agreement).(Sills, Robert) Modified on 12/7/2021 (jgo).

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Petitioner: Citigroup Inc.
Represented By: Robert L. Sills
Represented By: Ryan Adelsperger
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Respondent: Luis Sebastian Sayeg Seade
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