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Case 1:15-cv-10181-DJC Document 64 Filed 06/02/16 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS




ARDUINO, LLC,






Civil Action No.: 1:15-cv-10181-DJC







Plaintiff,


-v-


ARDUINO S.R.L. f/k/a SMART PROJECTS
S.R.L.; GHEO SA; CC LOGISTICS, LLC;
MAGYC NOW LTD; DOG HUNTER INC.; DOG
HUNTER LLC; DOG HUNTER AG; TULYP
HOLDING SA; GIANLUCA MARTINO;
FEDERICO MUSTO; and DOES 1-10,

Defendants.








MOTION TO EXTEND STAY OF DISCOVERY DEADLINES



Plaintiff Arduino, LLC respectfully submits this Motion to Extend Stay of Discovery




Deadlines. Plaintiff seeks a further stay of all discovery deadlines through July 8, 2016.

Plaintiff’s understanding is that the Judge in the co-pending Italian litigation strongly

suggested, and the Parties agreed, to suspend all pending actions against each other, but that

Defendants’ counsel has not yet received instruction from his clients regarding this motion.

The Parties first sought a joint stay of all deadlines on April 26, 2016 based on their

“substantial progress in reaching an agreement to resolve this matter.” Dkt. 60. Your Honor

granted this request with the Order of April 27, 2016. Dkt. 61. As reported in the Parties Joint

Status Report of May 27, 2016, negotiations are continuing but the agreement has not yet been

finalized. Dkt. 63. Plaintiff now seeks an extension of the stay through July 8, 2016 in order to

allow the Parties to continue negotiating a worldwide settlement agreement without the

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Case 1:15-cv-10181-DJC Document 64 Filed 06/02/16 Page 2 of 3



distraction and additional burden of litigation. Plaintiff will notify the Court regarding the status

of settlement at that time.





Respectfully submitted,



Dated: June 2, 2016 _/s/ Martin B. Schwimmer _
John L. Welch BBO#522040
Wolf, Greenfield & Sacks, P.C.
600 Atlantic Avenue
Boston, Massachusetts 02210-2206
Telephone: (617) 646-8000
Email:
[email protected]

Martin B. Schwimmer (pro hac vice)
Lori L. Cooper (pro hac vice)
LEASON ELLIS LLP
One Barker Avenue, Fifth Floor
White Plains, New York 10601
Telephone: (914) 288-0022
Email: [email protected]
[email protected]


Attorneys for Plaintiff




















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I certify that this document is being filed through the Court’s electronic filing system,

which serves counsel for other parties who are registered participants as identified on the Notice
of Electronic Filing (NEF). Any counsel for other parties who are not registered participants are
being served by first class mail on the date of electronic filing.



/s/ Lori L Cooper
Lori L. Cooper



Case 1:15-cv-10181-DJC Document 64 Filed 06/02/16 Page 3 of 3



CERTIFICATE OF SERVICE






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