Opinion
2:22-CV-00494-JAD-BNW 2:21 -cv-02184-JAD-BNW
02-08-2023
JONATHAN D. BLUM, ESQ. WILEY PETERSEN Samuel L. Butt Joshua D. Wurtzel SCHLAM STONE & DOLAN LLP
JONATHAN D. BLUM, ESQ.
WILEY PETERSEN
Samuel L. Butt
Joshua D. Wurtzel
SCHLAM STONE & DOLAN LLP
STIPULATION AND PROPOSED ORDER TO EXTEND DISPOSITIVE MOTION AND PRE-TRIAL ORDER DEADLINES
(SECOND REQUEST)
Plaintiffs John L. Suprock (“Mr. Suprock”), Laurie L. Suprock (“Mrs. Suprock”), Consortium LLC (“Consortium”), and Renewable Energy Now, LLC (“Renewable Energy” and, collectively, with Mr. Suprock, Mrs. Suprock, and Consortium, “Plaintiffs”) and Defendant Quantum Energy, Inc. (“Defendant” and, collectively with Plaintiffs, the “Parties”), 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 sixty (60) days to permit time for the Court to rule on the following pending motions: (1) Defendant's motion to dismiss (ECF No. 55); (2) Defendant's motion to strike (ECF No. 54); (3) Plaintiffs' motion strike (ECF No. 48); (4) Plaintiffs' motion to amend (ECF No. 49); and (5) Plaintiffs' motion to withdraw or supplement their motion for summary judgment (ECF No. 50) (the “Motions”).
1. Pursuant to LR IA 6-1, this is the Parties' second joint request to continue discovery deadlines in the Scheduling Order granted by this Court in the 22-CV-494 Action on June 27, 2022 (22-CV-494 ECF No. 24). Defendant previously moved to extend the deadline for the close of discovery to January 9, 2023, which extension Magistrate Judge Youchah granted. (See 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 ruled on, whichever is later) as the deadline for the Proposed Joint Pretrial Order. (ECF No. 51).
Deadlines that fall on a Sunday have been scheduled for the next judicial day.
2. 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
Discovery Cutoff
January 31, 2023
No change.
Dispositive Motions
Thursday, March 2, 2023
Monday, May 1, 2023
Pretrial Order
Monday, April 3, 2023
Monday, June 1, 2023 (or 30 days after the final dispositive motion is ruled on, whichever is later)
IT IS SO STIPULATED.
ORDER
IT IS SO ORDERED.