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Replies to post #661705 on NorthWest Biotherapeutics Inc (NWBO)
Re: Northwest Biotherapeutics Inc. v. Canaccord Genuity LLC, et al.,
No. 1:22-cv-10185
Dear Judge Woods:
We represent Plaintiff Northwest Biotherapeutics, Inc. in the above-captioned action and
write in response to Defendant Citadel Securities LLC’s letter (ECF 138) requesting a 30-day
extension of the deadline for Defendants to object to the Report & Recommendation (“R&R”)
issued by Magistrate Judge Stein (ECF 137).
Plaintiff does not believe an extension is necessary or warranted, as Defendants have long
been on notice of the exact issues covered by the R&R. The Amended Complaint, to which
Defendants’ motion to dismiss and the R&R is directed, was filed nearly nine months ago on April
10, 2023 (ECF 95). Defendants filed their motion to dismiss three months later on July 12, 2023
(ECF 114, 115), Plaintiff’s opposition was filed on August 25, 2023 (ECF 123), and Defendants
replied on September 27, 2023 (ECF 124). An extensive oral argument was held before Magistrate
Judge Stein on November 14, 2023.
Defendants claim that an extension is needed for them to coordinate among themselves,
but Defendants’ army of lawyers – seven firms and twenty-nine counsel of record – are more than
sufficiently equipped to timely respond to the same issues in the R&R that they briefed and argued
months ago.
While Plaintiff opposes an extension of the current briefing schedule, to the extent the
Court grants such an extension, Plaintiff respectfully requests that any extension of time to file
objections to the R&R apply to all parties, not just Defendants. The alignment of all parties’
deadlines to file objections will ensure that those objections, and any oppositions thereto, are
coordinated on a single schedule.
