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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF
MASSACHUSETTS


ARDUINO, LLC,


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.






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




JOINT MOTION TO EXTEND STAY OF DISCOVERY DEADLINES
The Parties respectfully submit this Joint Motion to Extend Stay of Discovery Deadlines,
seeking a further stay of all discovery deadlines through August 30, 2016.
Settlement negotiations between the Parties are continuing to progress. As noted in the
previous request to extend the stay,
dkt. 66, the Parties have agreed before the Judge in the co-
pending Italian litigation to continue the suspension of all pending actions between the Parties. 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. Plaintiff sought
a further extension of the stay which was not opposed by Defendants,
dkt. 64, and thereafter
Defendants consented to a stay through July 31, 2016,
dkt. 66. The Parties respectfully seek an
extension of the stay through
August 30, 2016
in order to allow the Parties to remain focused on Case 1:15-cv-10181-DJC Document 68 Filed 08/05/16 Page 1 of 3
negotiating the worldwide settlement agreement without the distraction of prosecuting this
litigation.

The Parties will notify the Court regarding the status of settlement at that time.



Respectfully submitted,


Dated: August 5, 2016


______/s/Michael P. Boudett____
Michael P. Boudett BBO#558757

Shrutih V. Ramlochan
-Tewarie BBO#685467
Foley Hoag LLP
155 Seaport Boulevard
Boston, MA 02210
Telephone:
(617) 832-1000
Email:
mboudett@foleyhoag.com
stewarie@foleyhoag.com

Attorneys for Defendants

_/s/ Martin B. Schwimmer _
John L. Welch BBO#522040
Wolf, Greenfield & Sacks, P
600 Atlantic Avenue
Boston, Massachusetts 02210
Telephone: (617)
646-8000
Email: John.Welch@WolfGr

Martin B. Schwimmer (
pro h
Lori L. Cooper (pro hac vice
LEASON ELLIS LLP
One Barker Avenue, Fifth Fl
White Plains, New York 106
Telephone: (914) 288-0022
Email: Schwimmer@Leason

Cooper@LeasonEllis

Attorneys for Plaintiff




Case 1:15-cv-10181-DJC Document 68 Filed 08/05/16 Page 2 of 3
CERTIFICATE OF SERVICE

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 68 Filed 08/05/16 Page 3 of 3