United States District Court, D. Nevada
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
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”). 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.
OF POINTS AND AUTHORITIES
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.
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.
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.
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
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.
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.
February 8, 2017, an Order was entered approving the
parties' proposed discovery plan and scheduling order.
ECF No. 135. The Order ...