Trial Date: November 1, 2011 Complaint Filed: June 11, 2010
JOINT MOTION TO MODIFY STATUS (PRETRIAL SCHEDULING) ORDER RE DATE TO COMPLETE DISCOVERY
NOW COMES Plaintiff ZACHARY HALLSTROM (hereinafter "Plaintiff") and Defendants AQUA FLORA, INC., and KING BIO, INC., (hereinafter "Defendants"), by and through their respective counsel, and hereby respectfully move this court for leave to modify the Court's Status (Pretrial Scheduling) Order dated November 17, 2010, specifically the date to complete discovery. In support of this joint motion, Plaintiff and Defendants state as follows:
1. On or about June 11, 2010, Plaintiff filed this Qui Tam action pursuant to 35 U.S.C. § 292(b).
2. The Court issued its Status (Pretrial Scheduling) Order November 17, 2010.
3. Pursuant to the Status (Pretrial Scheduling) Order, the parties are to complete discovery by February 9, 2011.
4. The parties have not completed discovery. Discovery is ongoing. The parties do not expect to be able to complete discovery by February 9, 2011.
5. The parties have discussed the continued discovery and have agreed to extend the date to complete discovery to March 25, 2011, subject to this Court's approval.
6. This modification should not have an impact on any other deadlines in this case, and neither party will be prejudiced by this extension.
WHEREBY, based on the foregoing reasons, Plaintiff and Defendants respectfully request that the Court modify its Status (Pretrial Scheduling) Order dated November 17, 2010, allowing the parties to extend the date to complete discovery to March 25, 2011.
Dated: January 27, 2011 NEWPORT TRIAL GROUP
Ryan M. Ferrell Attorneys for Plaintiff
Dated: January 27, 2011 LAW OFFICES OF ...