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

Document 74 Filed 02/15/18 Page 1 of 18

Exhibit A – Summary of NDIDA’s First Interrogatories 

Document 74-1 Filed 02/15/18 Page 1 of 6

Exhibit B – Summary of NDIDA’s First Requests for Production 

Document 74-2 Filed 02/15/18 Page 1 of 16

Exhibit C – Summary of NDIDA’s First Requests for Admission

Document 74-3 Filed 02/15/18 Page 1 of 16

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.