8:15-cv-00317-LES-TDT Doc # 112 Filed: 05/12/16 Page 1 of 4 - Page ID # 761

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEBRASKA
COR CLEARING, LLC, a Delaware limited
liability company,
Plaintiff,
Case No. 8:15-cv-317
vs.
STIPULATION AND JOINT
MOTION TO EXTEND
DEADLINES

CALISSIO RESOURCES GROUP, INC.,

a Nevada corporation; ADAM CARTER,
an individual; SIGNATURE STOCK
TRANSFER, INC., a Texas corporation;
and DOES 1-50,
Defendants.

COME NOW, Plaintiff, COR Clearing, LLC and Defendant, Signature Stock Transfer,
Inc.s (Signature Stock) and hereby stipulate as follows and hereby move the Court to extend
some of the deadlines in this action:
1.

The parties disclosure of expert witnesses is currently due on or before May 16,

2016 (Doc. No. 93);

2.

The parties hereby stipulate to extend the disclosure of expert witnesses, making

the parties new deadline to disclose expert witnesses due by July 1, 2016;
3.

The parties expert reports as required by Fed. R. Civ. P. 26(a)(2) are currently due

on or before June 1, 2016 and if necessary to refute the disclosed opinions of an expert witness
of an opponent, a party may disclose additional expert witnesses currently no later than June 22,
2016 (Doc. No. 93);
4.

The parties hereby stipulate to extend the deadline to provide expert reports as

required by Fed. R. Civ. P. 26(a)(2) to be due by July 1, 2016;

5.

Currently, if necessary to refute the disclosed opinions of an expert witness of an

1

8:15-cv-00317-LES-TDT Doc # 112 Filed: 05/12/16 Page 2 of 4 - Page ID # 762

opponent, a party may disclose additional expert witnesses no later than June 22, 2016;
6.

The parties hereby stipulate to extend the deadline to disclose additional expert

witnesses by no later than August 1, 2016, provided that the disclosing party then provides all of
the information described in Fed. R. Civ. P. Rule 26(a)(2) and makes the expert witness available
for deposition prior to the date set for completion of discovery;
7.

The deadline to amend pleadings and add parties to this action is currently June 1,

2016;
8.

The parties hereby stipulate to extend the deadline to amend pleadings and add

parties to this action to now be due by July 1, 2016;

9.

Currently the discovery deadline in which all discovery, whether or not intended

to be used at trial, shall be completed by July 1, 2016;

10.

The parties hereby stipulate to extend the discovery deadline in which all

discovery, whether or not intended to be used at trial, shall be completed by August 30, 2016;
11.

Currently any motion challenging the qualifications of an expert or the

admissibility of testimony of an expert witness under Rule 702, Fed. Rules of Evidence shall be
filed not later than July 15, 2016;
12.

The parties hereby stipulate to extend the deadline to file any motion challenging

the qualifications of an expert or the admissibility of testimony of an expert witness under Rule
702, Fed. Rules of Evidence to now be due by September 15, 2016;
13.

Currently, all motions for summary judgment are due to be filed on or before July

15, 2016;
14.

The parties hereby stipulate to extend the deadline to file all motions for summary

judgment on or before September 30, 2016;

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15.

This Stipulation and Motion is made within the original deadline established by the

Federal Rules of Civil Procedure and is not made for delay but so that justice may be done.
WHEREFORE, Plaintiff and Signature Stock respectfully and jointly move the Court to
extend each of the above deadlines in this action to now be due as follows:
a. Parties disclosure of expert witnesses due on or before July 1, 2016;
b. Parties expert reports as required by Fed. R. Civ. P. 26(a)(2) due on or before July 1,
2016;
c. Parties disclosure of rebuttal expert witnesses and information described in Fed. R.
Civ. P. Rule 26(a)(2) due no later than August 1, 2016;
d. Parties deadline to amend pleadings and add parties to this action due on or before
July 1, 2016;
e. All discovery, whether or not intended to be used at trial, shall be completed by
August 30, 2016;
f. The parties must file any motion challenging the qualifications of an expert or the
admissibility of testimony of an expert witness under Rule 702, Fed. Rules of
Evidence no later than September 15, 2016; and
g.

All motions for summary judgment shall be filed on or before September 15, 2016.

All other deadlines listed in this Courts Final Progression Order [Filing No. 93] would remain
in effect.

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Respectfully submitted,
Dated May 12, 2016.

By: /s Gail E. Boliver (with permission)

Gail E. Boliver
boliver@boliverlaw.com
BOLIVER LAW FIRM
2414 South 2nd Street
Marshalltown, IA 50158
Telephone (641) 752-6597

By: /s Michael T. Hilgers

Michael T. Hilgers (#24483)
mhilgers@goberhilgers.com
Carrie S. Dolton (#24221)
cdolton@goberhilgers.com
GOBER HILGERS PLLC
14301 FNB Parkway, Suite 100
Omaha, NE 68154
Telephone: (402) 218-2106
Facsimile: (877) 437-5755

Attorneys for Defendant Signature Stock

Transfer, Inc.

Attorneys for Plaintiff COR Clearing, LLC

CERTIFICATE OF SERVICE
I certify that on May 12, 2016, a true and exact copy of the foregoing was sent via
electronic mail through the CM/ECF system to all attorneys of record.
/s Michael T. Hilgers