Singh v. Deloitte LLP ( 2022 )

Morgan Lewis _ . “ + □ Pie brseden chee □ Brian T, Ortelere nef 4A ° a +1,215,963.5150 4 mpbiet, f bop [UO Date brian. ortelere@morganlewis.com Chg Lf eee © □□□ q J 2 ge 3 at □□ whe fon Pan, peed February 7, 2022 nth & MMe yo La Ce 4 “ 7 VIA ECF AND EMAIL We fein (FM o ef hay Mobi Hon. John G. Koeltl pee v “ A United States District Court “Ty of | ibe Southern District of New York (be po Seer f . Daniel Patrick Moynihan United States Courthouse ~ men ime A a £ iy = (ee 500 Pearl Street 4 witha teh Peat fos — eee ? - tp Ad New York, NY 10007-1312 Avtelies PS BE re P rca: BIULL pS, £ Re: Singh, et al. v. Deloitte, LLP, et al., 1:21-cv-08458 (JGK) a nol “ Dear Judge Koeltl: S eve bef, GEC, □ PS We represent Defendants Deloitte LLP, the Board of Directors of Deloitte LLP, and the Retirement 2 / Committee of Deloitte LLP (collectively, “Defendants”) in the above-referenced matter. We write □□ /9 ‘ pursuant to Rule 1(F) of Your Honor’s Individual Practices and with the consent of Plaintiffs’ counsel. We respectfully request an order setting forth the schedule for the briefing of Defendants’ response to the Complaint as agreed to by the parties and described below. On October 13, 2021, Plaintiffs filed the Complaint. On December 2, 2021, Defendants filed a motion to stay all proceedings pending a decision by the Supreme Court in Hughes v. Northwestern University (“Motion to Stay”} (ECF 20-21). The parties requested an adjournment of Defendants’ deadline to respond to the Complaint pending this Court’s decision on the Motion to Stay (ECF 22), On December 3, 2021, the Court entered an order granting the requested adjournment, and requiring the parties to submit a proposed schedule for Defendants to respond to the Complaint should the Court deny the Motion to Stay (ECF 23). On January 24, 2022, the Supreme Court issued a decision in Hughes, No. 19-1401, 2022 WL 199351 (U.S. Jan. 24, 2022), which moots the basis for Defendants’ request for a stay. Defendants have filed a motion to withdraw their Motion to Stay (ECF 29), In keeping with the Court’s order on December 3, 2021, the parties respectfully request the follawing schedule for briefing Defendants’ response to the Complaint: (a) Defendants will file a motion to dismiss or otherwise respond to the Complaint no later than March 18, 2022; (b) Plaintiffs will file an opposition to Defendants’ motion to dismiss no later than April 29, 2022; and (c) Defendants will file a reply in support of their motion to dismiss no later than May 20, 2022. The parties further request that the Court schedule an initial pre-trial conference on a date following the completion of the parties’ briefing on Defendants’ response to the Complaint. This request will not affect any other scheduled dates. Morgan, Lewis & Bockius LLP 1701 Markett Street Philadelphia, PA 19103-2921 @ +1.215.963,5917 United States @ +1.215.963,5001 Hon. John G. Koeltl February 7, 2022 Page 2 Thank you for your attention to this matter. Respectfully submitted, /5/ Brian T. Ortelere Brian T. Ortelere cc: All attorneys of record via ECF