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100 F Street, N.E. WASHINGTON, DC 20549 
Stephan J. Schlegelmilch Supervisory Trial Counsel Trial Unit, Mail Stop 5977 (202) 551-4935 (t) (301) 623-1184 (f) 
November 6, 2019 
By ECF and UPS 
Honorable Alvin K. Hellerstein United States District Judge Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, NY 10007-1312 Re: 
SEC v. Kik Interactive Inc.
, SDNY Case No. 19-cv-5244 (AKH)
 Dear Judge Hellerstein: Pursuant to Local Rule 37.2 and Rule 2(E) of Your Honor’s Individual Rules of Practice, the parties jointly write to request the Court’s permission to conduct seven depositions during the month of December 2019, after the November 29, 2019 fact discovery deadline set by the Court. Each of these third-party witnesses are represented by separate counsel, and the parties submit that these depositions, three of which require international travel, could not be scheduled during the discovery period due to the limited availability of the parties, the witnesses, and the witnesses’ counsel. Consequently, we jointly request permission to depose the following individuals at the identified times and places: 1.
Pat Chaukos – December 5, 2019 (Toronto) 2.
Ross McKee – December 10, 2019 (Washington, DC) 3.
Samuel Dowd – December 13, 2019 (Denver) 4.
Luc Hendriks – December 17, 2019 (Amsterdam) 5.
Harrison Wang – December 19, 2019 (Los Angeles) 6.
Ilan Leibovich – To be determined (Tel Aviv) 7.
 William Mougayar – To be determined (Washington, DC)
 Mr. Mougayar, his counsel, and the SEC staff are available to conduct Mr. Mougayar’s deposition in November, prior to the discovery cut-off date. Counsel for Kik has not yet informed the undersigned of their availability. 
Case 1:19-cv-05244-AKH Document 32 Filed 11/06/19 Page 1 of 2