You are on page 1of 4

8:15-cv-00317-LES-TDT Doc # 84 Filed: 12/04/15 Page 1 of 4 - Page ID # 604

UNITED STATES DISTRICT COURT


DISTRICT OF NEBRASKA
COR CLEARING, LLC, a Delaware limited liability ) Case No. 8:15-cv-00317-LES-FG3
company,
)
)
)
)
JOINT MOTION
Plaintiff,
)
)
vs.
)
)
CALISSIO RESOURCES, GROUP, INC., a Nevada )
corporation; ADAM CARTER, an individual;
)
SIGNATURE STOCK TRANSFER, INC., a Texas )
corporation; and DOES 1-50.
)
)
)
Defendants.

Plaintiff COR Clearing, LLC (COR Clearing) and Defendant Signature Stock Transfer
(Signature) hereby jointly move the Court, and would respectfully show as follows:
1.

On August 26, 2015, COR Clearing filed its Complaint against defendants,

including Defendant Signature Stock Transfer. (Dkt. No. 1.)


2.

On August 27, 2015, Plaintiff served Defendant Calissio Resources Group, Inc.

with process. (Dkt. No. 11.)


3.

Defendants Calissio Resources Group, Inc. and Adam Carter have not answered

or otherwise responded to the Complaint.


4.
29.)

On October 20, 2015, Defendant Signature filed a motion to dismiss. (Dkt. No.

8:15-cv-00317-LES-TDT Doc # 84 Filed: 12/04/15 Page 2 of 4 - Page ID # 605

5.

Pursuant to Federal Rule of Civil Procedure 16(b)(2), a scheduling order must

issue within 120 days after the first defendant is served with process, unless the Court orders
otherwise.
6.

Pursuant to Federal Rule of Civil Procedure 26(f), the parties must have a Rule

26(f) conference at least twenty-one (21) days before the Rule 16(b)(2) deadline.
7.

The parties have conferred pursuant to Rule 26(f) and stipulate and agree that

discovery may begin as to other defendants and third parties. Fed. R. Civ. P. 26(d), (f).
8.

In light of Signatures pending motion to dismiss, and in the interest in judicial

and party efficiency, the parties hereby move the Court for an extension of the deadline to submit
a Rule 26(f)(2) report until January 31, 2016, and to further extend the time for the initial
scheduling conference until after the Rule 26(f)(2) report has been submitted to the Court.
9.

The request is not made for delay but so that justice may be done.

10.

WHEREFORE, the parties respectfully and jointly move the Court to extend the

deadline to complete the Rule 26(f)(2) report until January 31, 2016.
Respectfully submitted,
Dated: December 4, 2015

By: s/ _Michael T. Hilgers_________


Michael T. Hilgers (#24483)
Carrie S. Dolton (#24221)
GOBER HILGERS PLLC
14301 FNB Parkway, Suite 100
Omaha, NE 68154
Telephone: 402.218.2106
Facsimile: 877.437.5755
mhilgers@goberhilgers.com
cdolton@goberhilgers.com
ATTORNEYS FOR PLAINTIFF COR
CLEARING, LLC

8:15-cv-00317-LES-TDT Doc # 84 Filed: 12/04/15 Page 3 of 4 - Page ID # 606

By: s/ _Gail E. Boliver (with permission)__


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

ATTORNEY FOR SIGNATURE STOCK


TRANSFER, INC.

8:15-cv-00317-LES-TDT Doc # 84 Filed: 12/04/15 Page 4 of 4 - Page ID # 607

CERTIFICATE OF SERVICE
The undersigned hereby certifies that on this 4th day of December 2015, a true and correct
copy of the foregoing was filed via the Courts CM/ECF System, and was served on all counsel of
record.

_s/ Michael T. Hilgers_______________