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Sonoro Invest S.A. v. Miller

United States District Court, D. Nevada

June 15, 2017

SONORO INVEST S.A., a Panamanian corporation, Plaintiff,
v.
ROBERT MILLER, an individual; ANDREW SHERMAN, an individual; COSTAS TAKKAS, an individual; and STEPHEN GOSS, an individual, Defendants, and ABAKAN, INC., a Nevada corporation, Nominal Defendant.

          JAMES PATRICK SHEA, ESQ. Nevada Bar No. 405 SCOTT D. FLEMING, ESQ. Nevada Bar No. 5638 ARMSTRONG TEASDALE LLP DAVID MARDER, ESQ., Massachusetts Bar No. 552485 (pro hac vice), SHERLI FURST, ESQ., New York Bar No. 4783577 (pro hac vice), MICHAEL A. KOLCUN, ESQ., New York Bar No. 5054127 (pro hac vice) ROBINS KAPLAN LLP Counsel for Plaintiff Sonoro Invest S.A.

          UNOPPOSED MOTION TO EXTEND DISCOVERY DEADLINES (First Request)

         Plaintiff Sonoro Invest S.A., (“Sonoro”) by and through its attorneys, Armstrong Teasdale LLP, hereby files this first Unopposed Motion to Extend Discovery Deadlines (the “Motion”). [1]This Motion is made and based upon the following Memorandum of Points and Authorities, the papers and pleadings on file herein, and any argument the Court may allow at the time of a hearing.

         MEMORANDUM OF POINTS AND AUTHORITIES

         I.

          INTRODUCTION

         The current Scheduling Order provides for the service of initial expert disclosures by August 3, 2017. Prior to preparing that disclosure, Sonoro anticipates needing to take certain depositions, which cannot occur until the document productions are complete. Since the parties are still exchanging documents, Sonoro does not anticipate being ready to make the expert disclosures in the time contemplated by the Scheduling Order, and requests that the Scheduling Order be extended by four months. Sonoro conferred with Defendants prior to filing this Motion to extend the discovery deadlines as set forth below, and the Defendants are in agreement and will not oppose the relief requested.

         II.

         PROCEDURAL BACKGROUND

         1. On December 3, 2015, Sonoro initiated this action by filing its Complaint. ECF No. 1. On December 29, 2015, Sonoro filed its operative First Amended Complaint. ECF No. 11.

         2. On March 31, 2016, an Order was entered approving a stipulated discovery plan and scheduling order as between Sonoro and Sherman. ECF No. 50. Miller and Takkas did not participate as they were not yet served, and Goss declined to do so. Id.

         3. On May 31, 2016, an Order was entered staying all discovery in light of the dispositive motions filed by Goss and Takkas. ECF No. 102. The Order provided that the parties must meet and confer and file a proposed discovery plan and scheduling order within fourteen days from the date of the order on the then-pending motions to dismiss, with discovery deadlines measured from the date of the order on the motions to dismiss. Id.

         4. On January 24, 2017, an Order was entered denying the motions to dismiss of Goss, Takkas, and Miller, and denying the motion to transfer venue of Sherman. ECF No. 129.

         5. On February 7, 2017, the parties submitted a proposed discovery plan and scheduling order. ECF No. 130. The parties requested special scheduling review to set the discovery deadlines for a period of 250 days given the complex nature of this case and the numerous and geographically diverse parties and witnesses, in addition to the fact that Takkas is confined to his home pending the outcome of a criminal case. Id.

         6. On February 8, 2017, an Order was entered approving the parties' proposed discovery plan and scheduling order. ECF No. 135. The Order ...


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