Ex. C

Case: 1:20-cv-03758 Document #: 67-3 Filed: 03/19/21 Page 1 of 5 PageID #:523
From: Burden, Ashley

To: "Jeremy Ruth"

Cc: Streit, Elizabeth M.; Patrick, Joseph J; Platt, Joseph

Subject: RE: [EXTERNAL] Re: CFTC v. Long Leaf Trading Group, Inc. et al., No. 20 cv 3758 (N.D. Ill.) | deposition of

Defendant Jeremy Ruth

Date: Friday, March 12, 2021 5:12:53 PM

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Mr. Ruth:

I hope this email finds you well. The CFTC cannot accommodate your request to extend the

discovery deadline through December 15, 2021. As you are aware, the CFTC and counsel for

Donelson and Long Leaf have agreed to propose a June 30, 2021 discovery deadline, pursuant to the

Court’s order of February 16, 2021. In communicating this agreement to the courtroom deputy, my

co-counsel, Mr. Platt, noted your objection to that deadline and your desire for a later one. 

With respect to your deposition, the CFTC cannot accept your refusal to commit to a date certain.

Please be advised that the CFTC will be filing a motion to compel your appearance at a remote

deposition on May 19, 2021, as per the revised notice of deposition. We will likely file some time

next week. You can of course obviate the need for our motion by proposing a reasonable deposition

date that falls within our proposed June 30 discovery deadline. 

Thanks,

A

Ashley J. Burden

Senior Trial Attorney/Chicago Regional Office

Division of Enforcement

Commodity Futures Trading Commission

O: (312) 596-0693

C: (312) 995-0779

aburden@cftc.gov

Case: 1:20-cv-03758 Document #: 67-3 Filed: 03/19/21 Page 2 of 5 PageID #:524
From: Jeremy Ruth <jeremysruth@hotmail.com> 

Sent: Friday, March 12, 2021 8:34 AM

To: Platt, Joseph <JPlatt@CFTC.gov>

Cc: Jim Falvey <jimfalvey@yahoo.com>; Streit, Elizabeth M. <estreit@CFTC.GOV>; Burden, Ashley

<ABurden@CFTC.gov>; Patrick, Joseph J <JPatrick@CFTC.gov>; 'adnelson0503@gmail.com'

<adnelson0503@gmail.com>

Subject: [EXTERNAL] Re: CFTC v. Long Leaf Trading Group, Inc. et al., No. 20 cv 3758 (N.D. Ill.) |

deposition of Defendant Jeremy Ruth

Joseph,

As I mentioned before I can not commit to a deposition date as I have not received any

discovery and it is unknown if I can view discovery in the format you have proposed that you

send it to me. Furthermore, in the event I receive discovery in the near future, me being 1

person and there being over 750K documents to review your timeline for my deposition, all

other depositions, and the fact discovery deadline is completely unrealistic for me to be

prepared to defend myself in this matter. 

With that said, I propose that the fact discovery deadline be pushed back to December 15th

2021. As for the scheduling of my deposition and all others, I propose that they be tabled till I

have received your productions and can confirm that I can access the documents in the

format produce to me. 

Please let me know your thoughts 

Sincerely,

Jeremy Ruth

From: Platt, Joseph <JPlatt@CFTC.gov>

Sent: Thursday, March 11, 2021 6:00 PM

To: Jeremy Ruth <jeremysruth@hotmail.com>

Cc: Jim Falvey <jimfalvey@yahoo.com>; Streit, Elizabeth M. <estreit@CFTC.GOV>; Burden, Ashley

<ABurden@CFTC.gov>; Patrick, Joseph J <JPatrick@CFTC.gov>; 'adnelson0503@gmail.com'

<adnelson0503@gmail.com>

Subject: RE: CFTC v. Long Leaf Trading Group, Inc. et al., No. 20 cv 3758 (N.D. Ill.) | deposition of

Defendant Jeremy Ruth

Mr. Ruth –

Case: 1:20-cv-03758 Document #: 67-3 Filed: 03/19/21 Page 3 of 5 PageID #:525
Please see the attached deposition notice concerning your deposition in the above-referenced case.

Joseph C. Platt

Trial Attorney, Division of Enforcement

Commodity Futures Trading Commission

C: 773-241-1543

jplatt@cftc.gov

From: Platt, Joseph 

Sent: Tuesday, March 9, 2021 11:42 AM

To: 'Jeremy Ruth' <jeremysruth@hotmail.com>

Cc: 'Jim Falvey' <jimfalvey@yahoo.com>; Streit, Elizabeth M. <estreit@CFTC.GOV>; Burden, Ashley

<ABurden@CFTC.gov>; Patrick, Joseph J <jpatrick@cftc.gov>

Subject: CFTC v. Long Leaf Trading Group, Inc. et al., No. 20 cv 3758 (N.D. Ill.) | deposition of

Defendant Jeremy Ruth

Mr. Ruth –

Given your request to reschedule your deposition, we are cancelling the court reporter for this

Friday and we will take your deposition at some as-yet-to-be-determined date in the near future.

Since you have not proposed an alternative date, we are proposing to reschedule your deposition for

the third week of May (5/17 – 5/21). If you have any conflicts during that week, let us know by this

Thursday, 3/11. If we don’t hear from you, we will send you a deposition notice for a date of our

choosing.

Relatedly, we have proposed to Defendants Long Leaf Trading Group and James Donelson to move

the fact discovery deadline back to June 30. Let us know by this Thursday, 3/11, if you have a

position on that proposed modification to the case’s scheduling order. If we do not hear back from

you by Thursday, 3/11, we will report to the Court that you do not have a position on the requested

change to the deadline.

Regards,

Joseph C. Platt

Trial Attorney, Division of Enforcement

Commodity Futures Trading Commission

C: 773-241-1543

jplatt@cftc.gov

Case: 1:20-cv-03758 Document #: 67-3 Filed: 03/19/21 Page 4 of 5 PageID #:526
Case: 1:20-cv-03758 Document #: 67-3 Filed: 03/19/21 Page 5 of 5 PageID #:527