Opinion
2:21-CV-02184-JAD-BNW 2:22-CV-00494-JAD-BNW
04-10-2023
FENNEMORE CRAIG, P.C. Christopher H. Byrd (No. 1633) Chelsie A. Adams (No. 13058) FENNEMORE CRAIG, P.C. David A. Timchak (Pro Hac Vice) Attorneys for Quantum Energy, Inc. WILEY PETERSEN Jonathan D. Blum, Esq. SCHLAM STONE & DOLAN LLP Samuel L. Butt (admitted pro hac vice) Joshua D. Wurtzel (admitted pro hac vice) Attorneys for the Suprock Parties
FENNEMORE CRAIG, P.C.
Christopher H. Byrd (No. 1633)
Chelsie A. Adams (No. 13058)
FENNEMORE CRAIG, P.C.
David A. Timchak (Pro Hac Vice)
Attorneys for Quantum Energy, Inc.
WILEY PETERSEN
Jonathan D. Blum, Esq.
SCHLAM STONE & DOLAN LLP
Samuel L. Butt
(admitted pro hac vice)
Joshua D. Wurtzel
(admitted pro hac vice)
Attorneys for the Suprock Parties
STIPULATION AND PROPOSED ORDER TO EXTEND DISPOSITIVE MOTION AND PRE-TRIAL ORDER DEADLINES
(THIRD REQUEST)
The Parties, Quantum Energy, Inc., John L. Suprock, Laurie L. Suprock, Consortium LLC, and Renewable Energy Now, LLC, by and through their counsel of record, jointly move the Court to continue the remaining deadlines for dispositive motions and the joint pre-trial order by thirty (30) days to permit time for the Court to rule on the motions listed in the Notice of Matters Ripe for Decision (Doc. 66):
(1) Doc- 48 (the Suprock parties' motion to strike Quantum's expert Brenda Hamilton),
(2) Doc. 49 (the motion to amend the Suprock parties' complaint), and
(3) Doc. 50 (the Suprock parties' motion to supplement or withdraw their summary judgment motion).
(4) Doc. 54 (Quantum Energy, Inc.'s motion to strike the Suprock parties' expert), and
(5) Doc. 55 (Quantum Energy, Inc.'s motion to dismiss the Suprock parties' complaint).(collectively, the “Motions”). The Parties request this extension as the resolution of these various motions will affect the scope and issues in any dispositive motion briefing.
Pursuant to LR IA 6-1, this is the Parties' third joint request to continue discovery deadlines in the Scheduling Order. Defendant previously moved to extend the deadline for the close of discovery to January 9, 2023, which extension Magistrate Judge Youchah granted. (22-CV-494 ECF No. 49). Following consolidation, this Court extended the close of discovery to January 31, 2023, and set March 2, 2023 as the deadline for dispositive motions, and April 2, 2023 (or 30 days after the final dispositive motion is rule on, whichever is later) as the deadline for the Proposed Joint Pretrial Order. (Doc. 51). Following this extension, the parties jointly moved the Court for another extension, which was granted by the Court, setting May 1, 2023 as the deadline for dispositive motions, and June 1, 2023 (or 30 days after the final dispositive motion is rule on, whichever is later) as the deadline for the Proposed Joint Pretrial Order. (Doc. 64).
It is respectfully submitted that the rulings on the Motions will affect the dispositive motions in this matter and thus, for efficiency's sake, briefing should not occur until the rulings are made. The continuance requested herein is not sought for the purposes of delay and will not result in prejudice to the Parties or the Court. Accordingly, the Parties jointly request that the Court continue all deadlines in accordance with the below schedule:
Deadline
Current Date
Proposed New Date
Dispositive Motions
May 1, 2023
June 2, 2023 (or 30 days after the last ruling on the Motions, whichever is later).
Pretrial Order
June 1, 2023
June 30, 2023 (or 30 days after the final dispositive motion is ruled on, whichever is later).
IT IS SO STIPULATED.
ORDER
IT IS SO ORDERED.