Cel Sci Corporation (CVM)

[sinity]

Two letters mailed back in May 2017

Quote is from a Letter that Plaintiffs Firm sent to Judge, dated May 23, 2017:

"Dear Judge Arpert:

We represent plaintiff Navigators Specialty Insurance Company. On May 21, 2017, the arbitrator in the underlying proceedings ordered Navigators to withdraw its motion for summary judgement and enjoined it from using any arbitration-related materials that are already in tis possession, including the transcript that supports Navigators' motion. PharmaNet has advised that it will not produce those materials in discovery. Therefore, Navigators must subpoena those record directly from CEL-SCI. Navigators hereby requests a 30 day extension of the discovery deadline in order to formally obtain those records, which the Court has already ruled are necessary to the full and fair adjudication of this action....."

Quote is from a Letter that Defendents Firm sent to Judge, dated May 26, 2017:

"Dear Judge Arpert:

This firm represents the Defendants ("PharmaNet") in the above referenced matter......As indicated in Mr. Rosenberg's letter of May 23, 2017, Navigators' previously-pending motion for summary judgement has been withdrawn pursuant to the order of the underlying arbitrator. Thus, the parties need not confer regarding a briefing schedule for that motion. However, Navigators has indicated that it intends to subpoena the underlying claimant (CEL-SCI) to obtain copies of the arbitration transcripts and seeks an extension of discovery to do so. The parties agree that it would be most efficient for the Court to rule upon PharmaNet's motion to stay before any efforts are made to subpoena CEL-SCI or pursue additional discovery, so as to avoid unnecessary costs or discovery motion practice. Therefore, the parties request that the Court extend the discovery deadline until 45 days after a decision is issued on the motion to stay so as to allow the parties time to pursue any necessary subpoenas for underlying arbitration materials if the case is not stayed outright."

From my previous post Motion to Stay was granted on July 24, 2017

Letter retrieved from https://ecf.njd.uscourts.gov