Pam

🚨Buzbee defendants asked judge Ho for a 60 day extension of discovery On November 3, the Buzbee Defendants filed a letter asking Judge Dale Ho to extend the deadlines in the current case management schedule by approximately 60 days. The Curis Defendants have joined the request. This is the Defendants’ first request for an extension. However, the parties are not in agreement on how much additional time is needed. According to the letter, Jay Z’s side is willing to accept a 30 day extension with conditions, but opposes the Defendants’ request for 60 days. The Defendants argue that additional time is necessary to complete discovery in an orderly manner. They point to several issues: 1. More than 15 depositions have been noticed, but none have been definitively scheduled. The Defendants say coordinating the schedules of the parties and numerous nonparty witnesses has been difficult, particularly with the remaining discovery period overlapping with the holiday season. They also say that Jay Z has not provided dates for his own deposition, despite multiple requests, and that the Buzbee parties have faced difficulty coordinating depositions of the Defendants. 2. Disputes over the Jay Z’s discovery responses remain unresolved. The Buzbee Defendants say they raised deficiencies in the Plaintiff’s responses to their document requests on October 1. Two areas of dispute are particularly important to them: documents concerning the retention of investigators who interviewed Jane Doe at her home on February 21, 2025, and documents supporting the Plaintiff’s claimed damages. According to the letter, the parties met and conferred on October 13, but the Plaintiff did not provide a substantive response until November 2. The Defendants argue that further discussions, and potentially court intervention, will be necessary before they can obtain the discovery they are seeking. 3. The current schedule could require discovery to close before the case is even fully at issue. Judge Ho has scheduled oral argument on the pending motions to dismiss and strike the Third Amended Complaint for December 11. The Defendants argue that if any part of those motions is denied, they may have 14 days to answer and assert counterclaims. That could leave the parties with little or no time to conduct discovery related to those pleadings before the existing discovery deadline. The letter also provides a breakdown of document productions. Jay Z made several productions, including 3,185 documents on October 28 and another 1,653 documents on October 29. The Buzbee Defendants report producing 184 documents on October 9 and 46 documents, along with a privilege log, on October 22. No depositions have taken place. WHAT ARE THE DEFENDANTS ASKING FOR? They propose moving the fact discovery deadline from December 31, 2026, to February 26, 2027. They also want the expert disclosure and expert discovery deadlines moved, with expert discovery concluding April 30, 2027. The proposed schedule would move the joint status letter to May 7, 2027, with the next case management conference to be set by the Court. The Buzbee Defendants also cite lead counsel’s maternity leave as one of the logistical challenges affecting deposition scheduling. Counsel states that she gave birth four months ago and is technically still on leave. The letter concludes by arguing that a 60 day extension would give all parties sufficient time to complete discovery and reduce the likelihood of having to request another extension. It also accuses Jay Z’s side of seeking to run out the clock on discovery into his damages allegations. Important: This is a request, not an order. Judge Ho has not yet granted or denied the requested extension. The current deadlines remain in place unless and until the Court changes them.