FIRST LETTER MOTION to Stay Proceedings addressed to Judge John G.… — United States v. Visa Inc. (Dkt. 115)

Summary

Letter dated October 1, 2025 to the Honorable John G. Koeltl in which the United States moves for a temporary stay of the case until appropriations for the Department of Justice are restored. It states that the appropriations act that had been funding the Department of Justice expired at the end of the day on September 30, 2025. The United States requests that all current deadlines be extended by the total number of days of the lapse in appropriations. It states that Visa does not oppose the motion to the extent it seeks to stay court-imposed deadlines but requests that any stay not cover negotiations and obligations related to third-party document subpoenas issued by Visa. The letter is signed /s/ Craig W. Conrath.

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1 
 
 
Liberty Square Building 
 
450 5th Street, N.W. 
Washington, DC 20530 
 
 
 
 
 
 
 
      
 
 
Via ECF 
 
 
 
 
 
 
 
The Honorable John G. Koeltl 
October 1, 2025 
Daniel Patrick Moynihan U.S. Courthouse 
500 Pearl St., Courtroom 14A 
New York, NY 10007 
 
Re:     United States v. Visa, Inc., et al., Case No. 1:24-cv-07214 (JGK-SLC) 
 
MOTION FOR STAY OF PROCEEDINGS 
DUE TO LAPSE OF APPROPRIATIONS 
Dear Judge Koeltl: 
 
Pursuant to this Court’s Individual Rules I (A) and (E), the United States hereby moves 
for a temporary stay of the above-captioned case until appropriations for the Department of 
Justice are restored and Department of Justice attorneys are permitted to resume their usual civil 
litigation functions. 
 
At the end of the day on September 30, 2025, the appropriations act that had been funding 
the Department of Justice expired and appropriations to the Department lapsed. The Department 
does not know when such funding will be restored by Congress. 
 
Absent an appropriation, Department of Justice attorneys and employees are generally 
prohibited from working, even on a voluntary basis, except in very limited circumstances such 
as “emergencies involving the safety of human life or the protection of property.” 31 U.S.C. 
§ 1342.  
 
If this motion is granted, the United States will notify the Court as soon as Congress has 
appropriated funds for the Department. The Government requests that, at that point, all current 
deadlines for the parties be extended commensurate with the duration of the lapse in 
appropriations—i.e., each deadline would be extended by the total number of days of the lapse in 
appropriations. As the Court is aware, the parties are currently engaged in fact discovery (see ECF 
No. 100 dated August 1, 2025).   
 
Visa has authorized the United States to represent that Visa does not oppose the 
Case 1:24-cv-07214-JGK     Document 115     Filed 10/01/25     Page 1 of 2

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government’s motion to the extent it seeks to stay court-imposed deadlines, but requests that any 
stay imposed by the Court not cover negotiations and obligations related to third-party document 
subpoenas issued by Visa. 
 
Under these exigent circumstances, and in the absence of any party objection, the United 
States respectfully requests that the Court grant the motion to stay without a formal motion and 
without a conference with the Court. Of course, we stand ready to appear or answer any 
questions the Court may have as needed. 
 
We greatly regret any disruption caused by these circumstances and appreciate the 
Court’s consideration of this request. 
 
Respectfully submitted, 
/s/ Craig W. Conrath  
Craig W. Conrath 
Lead Trial Counsel 
United States Department of Justice 
Antitrust Division 
450 Fifth Street N.W., Suite 4000 
Washington, DC 20530 
Telephone: (202) 375-4843 
Facsimile: (202) 514-7308 
Email: Craig.Conrath@usdoj.gov 
 
Attorney for Plaintiff  
United States of America 
 
cc: 
All counsel via ECF 
Case 1:24-cv-07214-JGK     Document 115     Filed 10/01/25     Page 2 of 2

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