AEM vs North Dakota – Opposition to Defendants’ Motion for Stay
Case 1:17-cv-00151-DLH-CSM
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NORTH DAKOTA
AEM vs North Dakota
AEM OPPOSITION TO DEFENDANTS’ MOTION TO STAY
Exhibit A – Summary of NDIDA’s First Interrogatories
Exhibit B – Summary of NDIDA’s First Requests for Production
Exhibit C – Summary of NDIDA’s First Requests for Admission
AEM's CONCLUSION Defendants should be held to the schedule for fact discovery, expert discovery, dispositive motions, and—if necessary—trial to which they agreed in November. Defendants have not met their burden of making the “strong showing” necessary merely to stay discovery, much less this entire litigation. The Manufacturers therefore respectfully request that Defendants’ motion for stay be denied.