UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

MISH INTERNATIONAL MONETARY INC., 

on behalf of itself and 

all others similarly situated, 

Plaintiff, 

v. 

VEGA CAPITAL LONDON, LTD., and JOHN 

DOES 1-100, 

Defendants.

Case No. 1:20-cv-04577 

DEFENDANT VEGA CAPITAL LONDON, LTD.’S AGREED MOTION 

FOR LEAVE TO FILE BRIEFS IN EXCESS OF FIFTEEN PAGES 

Defendant, Vega Capital London, Ltd. (“Vega”), by its undersigned counsel and in 

accord with Local Rule 7.1, hereby moves to modify the page limits set forth in Local Rule 7.1 

for the briefing relating to Vega’s upcoming motion to dismiss the Class Action Complaint filed 

by Plaintiff Mish International Monetary Inc. (“Plaintiff”). In support of this motion, Vega states 

as follows: 

1. On August 4, 2020, Plaintiff filed a five count class action complaint alleging 

violations of the Commodities Exchange Act (7 U.S.C. § 1 et seq.) and the Sherman Act (15 

U.S.C. § 1 et seq.), relating to the trading of WTI crude oil futures on April 20, 2020, a day when 

the crude oil futures price traded at a negative price. 

2. Vega plans to file a motion to dismiss under Rule 9(b) and 8(a) of the Federal 

Rules of Civil Procedure. The motion will address, among other things, whether Plaintiff has 

adequately alleged under the Commodity Exchange Act that (1) Vega or the traders possessed 

the ability to influence prices of crude oil futures on April 20, 2020; (2) an artificial price 

existed; (3) Vega or the traders caused the artificial price; and (4) Vega or the traders specifically 
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intended to cause the artificial price. The motion will further address whether Plaintiff has 

adequately alleged the elements of a claim under the Sherman Act: (1) the existence of a 

contract, combination, or conspiracy; (2) an unreasonable restraint of trade as a result of the 

agreement; and (3) an injury to the Plaintiff. In this motion, Vega will have to address the 

unique market circumstances surrounding the trading of crude oil on April 20, 2020 (including 

the global pandemic, the effects of the pandemic on the world's economy, the over-supply of oil, 

the lack of storage space, stay-at-home orders, among many other factors), all of which Plaintiff 

neglected to mention in its complaint and of which the Court can take judicial notice. 

3. Judges of this Court have granted leave to exceed the page limits in other 

Commodities Exchange Act cases, permitting defendants to file comparable motions to dismiss 

with a page limit of 30 pages or more. See, e.g., U.S. Commodity Futures Trading Commission 

v. Kraft Foods Group, Inc., Civil Action No. 15-2881, Docket Entry No. 40 (N.D. Ill.) 

(permitting a 30 page motion to dismiss for two counts of a Commodity Exchange Act 

complaint); Ploss v. Kraft Foods Group, Inc., Civil Action No. 15-2937, Docket Entry No. 74 

(N.D. Ill.) (granting leave to file a 35 page motion to dismiss). 

4. Vega has conferred with counsel for Plaintiff about Vega's motion. The parties 

agreed to seek leave under Local Rule 7.1 to extend the page limit for the briefs related to Vega's 

motion to dismiss as follows: 

• Thirty (30) pages for Vega’s memorandum in support of its motion to dismiss; 

• Thirty-five (35) pages for Plaintiff’s response to Vega’s motion to dismiss; and 

• Fifteen (15) pages for Vega’s reply brief in support of its motion to dismiss. 
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WHEREFORE Defendant Vega Capital London, Ltd. respectfully requests that this Court 

modify the page limits for the briefs relating to Vega’s motion to dismiss to permit Vega to file a 

thirty (30) page memorandum in support, Plaintiff to file a thirty-five (35) page memorandum in 

response, and Vega to file a fifteen (15) page reply brief in support of its motion to dismiss. 

Dated: November 24, 2020 Respectfully submitted, 

VEGA CAPITAL LONDON, LTD. 

By: /s/ Amy Graham Doehring 

One of its attorneys 

Amy Graham Doehring 

AKERMAN LLP 

71 S. Wacker Drive, 47th Floor 

Chicago, IL 60606 

(312) 634-5700 

amy.doehring@akerman.com

Michael P. Kelly 

AKERMAN LLP 

750 Ninth Street, N.W., Suite 750 

Washington, DC 20001 

(202) 393-6222 

michael.kelly@akerman.com

Joel S. Forman 

Meghan K. Boland 

AKERMAN LLP 

520 Madison Avenue, 20th Floor 

New York, NY 10022 

(212) 880-3800 

joel.forman@akerman.com

meghan.boland@akerman.com
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CERTIFICATE OF SERVICE 

I, Amy Graham Doehring, an attorney, hereby certify that on November 24, 2020, I 

electronically filed the foregoing with the Clerk of the Court using the CM/ECF system, which 

will send a notice of electronic filing via electronic mail to all attorneys of record. 

/s/ Amy Graham Doehring

Amy Graham Doehring