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Re: None

Tuesday, 08/11/2015 10:44:44 AM

Tuesday, August 11, 2015 10:44:44 AM

Post# of 15274
Well, ain't that just dandy...

Most recent GEOMC filing:

"Plaintiff GEOMC Co., Ltd. (“GEOMC”) hereby moves for an order amending theScheduling Order Regarding Case Management Plan (“Scheduling Order”) entered by Judge Victor Bolden on June 15, 2015 [Doc. No. 78]. Defendant Calmare Therapeutics Inc. (“CTI”) is
currently not represented by counsel, and has failed to retain successor counsel to Greenberg & Traurig LLP on or before July 6, 2015 in accordance with the Court’s Order dated June 15, 2015
[Doc. No. 78].

CTI is further a corporate entity and cannot represent itself pro se in this action. Therefore GEOMC has been unable to meet and confer with CTI to request its consent to GEOMC’s present motion to modify the Scheduling Order. GEOMC represents that good cause
exists to modify the dates set forth in the Scheduling Order, and respectfully requests that the deadlines in the Scheduling Order be extended for a period of approximately twelve weeks.

In support of the motion, GEOMC states as follows:

1. On July 6, 2015, pursuant to Local Rule 7(c) and this Court’s Order dated June 15, 2015 [Doc. No. 78], Attorney Robert A. Horowitz of the law firm Greenberg Tarurig LLP withdrew as counsel for CTI. [Doc. No. 90].

2. Since July 6, 2015, CTI has not retained successor counsel, and as a corporate entity, cannot represent itself pro se in this action.

3. Accordingly, GEOMC has been unable to meet and confer with CTI in an attempt to obtain CTI’s consent to the proposed modification of the Scheduling Order. Aside from the limited deposition of Conrad Mir conducted pursuant to the Court’s Order dated June 15, 2015 permitting expedited discovery in relation to GEOMC’s Motion for a Temporary Restraining Order, the parties have not taken depositions of any party or non-party witnesses.

4. In light of the substantial number of party and non-party depositions that will need to be taken, and the fact that discovery has been – and continues to be – delayed due to the
absence of CTI’s counsel, GEOMC requests that Scheduling Order be amended to extend each of the deadlines as follows:

...Discovery Deadline from October 14, 2015 to January 6, 2016.

...Disclosure Deadline for Expert Reports from August 12, 2015 to November 4, 2015.

...Discovery Relating to Expert Witnesses from October 14, 2015 to January 6, 2016.

...Damage Analysis from September 11, 2015 to December 4, 2015.

...Mandatory Settlement Conference from November 2015 to February 2016.

...Joint Trial Memorandum from February 12, 2016 to May 6, 2016.

...Request for a Prefiling Conference Regarding a Motion for Summary Judgment from August 28, 2015 to November 20, 2015.

...GEOMC proposes the deposition of fact witnesses be completed by Nov 4, 2015, and..."

I don't get it -- CTTC was under court order to retain new council and they didn't, yet there's no penalty?????

In any case, it looks like the lawyers are going to milk this thing for all its worth!

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