UPDATE on the EMA lawsuit posted today at court: I see this as positive and ordinary--and it agrees with what I previously stated:
O L S H A N 1325 AVENUE OF THE AMERICAS ~ NEW YORK, NEW YORK T 0019 TELEPNOPlE: 212.451.2300 ~ fACSIMfLE: 212.451.2222
EMAIL: TFLEMING@OLSHANLAW.COM DIRECT DIAL: 212.451.2213
June 22, 2018
BY ECF AND FACSIMILE: 212-805-7927
Hon. Naomi Reice Buchwald United States Courthouse 500 Pearl Street New York, New York 10007
Re: EMA Financial, LLC v. nFUSZ, Inc. Civil Action No. 1:18 cv 03634 (NRB)
Dear Judge Buchwald:
VVe are counsel for Plaintiff and, pursuant to the Court's June 18, 2018 Order, the parties have conferred and agreed as follows.
Defendant shall file its answer to the Complaint no later than July 6, 2018.
In lieu of a Rule 16 conference, the parties have agreed that all discovery shall be completed by October 26, 2018, with document discovery to be completed by August 31, 2018. Initial disclosures shall be exchanged no later than July 13, 2018 and document requests shall be served no later than July 20, 2018. Each party may move for summary judgment after documents have been produced, but such motions shall not stay further discovery. The parties believe that the case is appropriate for mediation after discovery has been completed and would prefer mediation through the SDNY Mediation program.
We respectfully request that the Court approve the foregoing.
Respectively submitted,
~~,
Thomas J. Fleming
Enclosure
cc: Mark R. Basile, Esq. (Via ECF and Fax: 631-498-0478
d L S Fi A ~! F R d M E W O L O S K Y L L P
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