On June 09, 2020 a
Order
was filed
involving a dispute between
Deutsche Bank Ag,
and
Alexander Vik,
Caroline Vik,
for T90 - Torts - All other
in the District Court of Fairfield County.
Preview
DOCKET NO.: FST-CV20-6047029-S : SUPERIOR COURT
:
DEUTSCHE BANK AG, : JUDICIAL DISTRICT OF
: STAMFORD/NORWALK
Plaintiff, : AT STAMFORD
v. :
: December 2, 2021
CAROLINE VIK, ET AL., :
:
Defendants. :
:
MOTION ON CONSENT TO MODIFY CASE MANAGEMENT ORDER
Plaintiff Deutsche Bank AG moves with the consent of Defendants Caroline Vik and
Alexander Vik for a modification of the Court’s Case Management Order (Dkt. No. 160.01), as
set forth in the Joint Proposed Revised Case Management Order attached as Exhibit A to this
Motion. Specifically, the parties seek to extend the time in which to depose jurisdictional fact
witnesses from December 30, 2021 to February 15, 2022. The proposed modification will not
affect any of the other provisions, including the March 4, 2022 hearing date. This is the parties’
first joint motion for modification of the Court’s Case Management Order.
The parties respectfully request additional time in which to depose jurisdictional fact
witnesses in order to allow sufficient time for the Court to consider and rule upon Defendant
Alexander Vik’s pending Motion for a Protective Order (Dkt. No. 165.00) before Defendants’
depositions are taken. In addition, the current timeframe for depositions of jurisdictional fact
witnesses coincides with a number of holidays, rendering the scheduling of such depositions
challenging, and the proposed modification also will accommodate the schedule of Defendants’
counsel who has a trial in another action scheduled for early January. As noted, the modification
will not delay the resolution of the pending motions to dismiss. Accordingly, good cause exists
for granting this Motion and the requested modification and extension.
WHEREFORE, the parties respectfully request that the Court modify its Case
Management Order as set forth in the attached Joint Proposed Revised Case Management Order,
including an extension of time in which to depose jurisdictional fact witnesses from December
30, 2021 to February 15, 2022.
DEFENDANTS CAROLINE VIK AND PLAINTIFF DEUTSCHE BANK AG
ALEXANDER VIK
By: /s/ Monte E. Frank By: /s/ David G. Januszewski
Monte E. Frank David G. Januszewski
Johanna S. Katz Juris No. 403654
Pullman & Comley, LLC Sheila C. Ramesh
850 Main Street P.O. Box 7006 Juris No. 435593 (PHV)
Bridgeport, CT 06601-7006 Cahill Gordon & Reindel LLP
T: 203-330-2000 32 Old Slip
F: 203-576-8888 New York, New York 10005
djanuszewski@cahill.com
Attorneys for Defendants Caroline sramesh@cahill.com
Vik and Alexander Vik T: 212-701-3000
F: 212-269-5420
Thomas D. Goldberg
Jennifer M. Palmer
Day Pitney LLP
One Stamford Plaza
263 Tresser Boulevard, 7th Floor
Stamford, Connecticut 06901
tgoldberg@daypitney.com
jpalmer@daypitney.com
T: 203-977-7300
F: 203-977-7301
Juris No. 014230
Attorneys for Plaintiff Deutsche Bank AG
-2-
.
CERTIFICATION
This is to certify that a true and correct copy of the foregoing was or will immediately be
mailed or delivered electronically or non-electronically on December 2, 2021 to all counsel and
self-represented parties of record and that written consent for electronic delivery was received
from all counsel and self-represented parties of record who were or will immediately be
electronically served.
/s/ Jennifer M. Palmer
Jennifer M. Palmer
-3-
.
EXHIBIT A
JOINT PROPOSED REVISED SCHEDULING ORDER
1. The parties shall produce responsive documents and answer all interrogatories by
10/15/21;
2. Depositions of all jurisdictional fact witnesses shall be conducted by 2/15/22;
3. The parties shall disclose any experts, if any, relating to the jurisdictional issues
before the Court by 1/14/22;
4. Depositions of any jurisdictional experts shall be conducted by 2/15/22; and
5. Hearing on Motions to Dismiss and to Stay relating to jurisdictional issues is
scheduled for 3/4/22 at 10:00 a.m.
-4-
.
Document Filed Date
December 02, 2021
Case Filing Date
June 09, 2020
Category
T90 - Torts - All other
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DOCKET NO.: FST-CV20-6047029-S : SUPERIOR COURT : DEUTSCHE BANK AG, : JUDICIAL DISTRICT OF : STAMFORD/NORWALK Plaintiff, : AT STAMFORD v. : : December 2, 2021 CAROLINE VIK, ET AL., : : Defendants. : : MOTION ON CONSENT TO MODIFY CASE MANAGEMENT ORDER Plaintiff Deutsche Bank AG moves with the consent of Defendants Caroline Vik and Alexander Vik for a modification of the Court’s Case Management Order (Dkt. No. 160.01), as set forth in the Joint Proposed Revised Case Management Order attached as Exhibit A to this Motion. Specifically, the parties seek to extend the time in which to depose jurisdictional fact witnesses from December 30, 2021 to February 15, 2022. The proposed modification will not affect any of the other provisions, including the March 4, 2022 hearing date. This is the parties’ first joint motion for modification of the Court’s Case Management Order. The parties respectfully request additional time in which to depose jurisdictional fact witnesses in order to allow sufficient time for the Court to consider and rule upon Defendant Alexander Vik’s pending Motion for a Protective Order (Dkt. No. 165.00) before Defendants’ depositions are taken. In addition, the current timeframe for depositions of jurisdictional fact witnesses coincides with a number of holidays, rendering the scheduling of such depositions challenging, and the proposed modification also will accommodate the schedule of Defendants’ counsel who has a trial in another action scheduled for early January. As noted, the modification will not delay the resolution of the pending motions to dismiss. Accordingly, good cause exists for granting this Motion and the requested modification and extension. WHEREFORE, the parties respectfully request that the Court modify its Case Management Order as set forth in the attached Joint Proposed Revised Case Management Order, including an extension of time in which to depose jurisdictional fact witnesses from December 30, 2021 to February 15, 2022. DEFENDANTS CAROLINE VIK AND PLAINTIFF DEUTSCHE BANK AG ALEXANDER VIK By: /s/ Monte E. Frank By: /s/ David G. Januszewski Monte E. Frank David G. Januszewski Johanna S. Katz Juris No. 403654 Pullman & Comley, LLC Sheila C. Ramesh 850 Main Street P.O. Box 7006 Juris No. 435593 (PHV) Bridgeport, CT 06601-7006 Cahill Gordon & Reindel LLP T: 203-330-2000 32 Old Slip F: 203-576-8888 New York, New York 10005 djanuszewski@cahill.com Attorneys for Defendants Caroline sramesh@cahill.com Vik and Alexander Vik T: 212-701-3000 F: 212-269-5420 Thomas D. Goldberg Jennifer M. Palmer Day Pitney LLP One Stamford Plaza 263 Tresser Boulevard, 7th Floor Stamford, Connecticut 06901 tgoldberg@daypitney.com jpalmer@daypitney.com T: 203-977-7300 F: 203-977-7301 Juris No. 014230 Attorneys for Plaintiff Deutsche Bank AG -2- . CERTIFICATION This is to certify that a true and correct copy of the foregoing was or will immediately be mailed or delivered electronically or non-electronically on December 2, 2021 to all counsel and self-represented parties of record and that written consent for electronic delivery was received from all counsel and self-represented parties of record who were or will immediately be electronically served. /s/ Jennifer M. Palmer Jennifer M. Palmer -3- . EXHIBIT A JOINT PROPOSED REVISED SCHEDULING ORDER 1. The parties shall produce responsive documents and answer all interrogatories by 10/15/21; 2. Depositions of all jurisdictional fact witnesses shall be conducted by 2/15/22; 3. The parties shall disclose any experts, if any, relating to the jurisdictional issues before the Court by 1/14/22; 4. Depositions of any jurisdictional experts shall be conducted by 2/15/22; and 5. Hearing on Motions to Dismiss and to Stay relating to jurisdictional issues is scheduled for 3/4/22 at 10:00 a.m. -4- .