Wednesday, September 28, 2016 9:52:36 AM
I read through all of the emails exchanged (that made it into the exhibits) and I never saw this...
Please provide PROOF of this claim.
So this is all BULLSHIT too...
you're basing an argument on something that is FALASE.
AND TAUG KNEW it would take longer, even IF it remained in Florida...
Their purposed schedule for discovery...
"Plaintiff proposed that the discovery completion deadline be April 7, 2017 in its draft of the 26(f) conference statement."
"As recently as late July, Plaintiff’s counsel recognized that it would take until the end of July, 2017 to complete discovery. Had Plaintiff’s counsel filed the Rule 26 report with Plaintiff’s proposed discovery schedule, Magistrate Judge Brannon would presumably have set a discovery schedule comporting with the complexities of the case and its current status..."
I suggest you read all the exhibits previously filed...
"Defendants incorporate herein by reference their Memorandum in Opposition to Plaintiff’s Motion to Compel Discovery and Renewed Motion for Protective Order (Docket No. 38) (the “Response”) and specifically paragraphs 12-41 of the Response and all exhibits to the Response incorporated into those paragraphs which more fully detail the communications between Plaintiff’s and Defendants’ counsel that induced Defendants to hold off on discovery pending the anticipated transfer to the District of New Jersey."
Case 0:15-cv-62334
ROTFLMAO
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