Case 9:18-cv-80176-BB Document 284 Entered on FLSD Docket 09/17/2019 Page 1 of 3



                                UNITED STATES DISTRICT COURT
                                SOUTHERN DISTRICT OF FLORIDA

  IRA KLEIMAN, as personal representative of
  the estate of David Kleiman, and W&K INFO
  DEFENSE RESEARCH, LLC

          plaintiffs,
  v.                                                              Case No. 9:18-cv-80176 (BB/BR)

  CRAIG WRIGHT,

        defendant.
  _____________________________________/

                                        JOINT MOTION
                        FOR A 30-DAY EXTENSION OF ALL DISCOVERY AND
                             CASE DEADLINES, AND TRIAL SETTING

          The parties are currently engaged in good faith settlement discussions. To that end, Dr.

  Wright and Plaintiffs respectfully request a 30-day extension of all discovery and case deadlines to

  facilitate these discussions. In support of this request, the parties state as follows:

          1.      The parties have been engaged in extensive settlement negotiations and have reached

  a non-binding agreement in principle to settle this matter.

          2.      The parties are continuing to negotiate, finalize all relevant terms, and document the

  agreement appropriately.

          3.      In the meantime, however, many important case deadlines are quickly approaching.

  For example, expert disclosures are due on November 5, 2019, the discovery cutoff is set for

  December 3, 2019, Dr. Wright’s opposition to Judge Reinhart’s sanctions order is due on September

  24, 2019, and Plaintiffs’ motion for attorneys’ fees is due on September 20, 2019.

          4.      Reaching a final binding settlement agreement is in the best interests of both parties,

  and a 30-day extension of all case deadlines (including the trial setting) would enable both parties

  to devote their full efforts to that goal.
Case 9:18-cv-80176-BB Document 284 Entered on FLSD Docket 09/17/2019 Page 2 of 3



            5.     For the foregoing reasons, both parties jointly move for a 30-day extension of all

  discovery and case deadlines.

            6.     This motion is brought in good faith and not for the purposes of delay.

                         CERTIFICATE OF GOOD FAITH CONFERENCE

            Pursuant to Local Rule 7.1(a)(3), I certify that counsel for the movant has conferred with

  all parties who may be affected by the relief sought in this motion. All parties agree to the relief

  sought.


   Attorneys for Plaintiffs                           Attorneys for Dr. Craig Wright

   s/ Velvel (Devin) Freedman                         RIVERO MESTRE LLP
   Velvel (Devin) Freedman, Esq.                      2525 Ponce de Leon Boulevard, Suite 1000
   ROCHE FREEDMAN LLP                                 Miami, Florida 33134
   200 S. Biscayne Blvd.                              Telephone: (305) 445-2500
   Suite 5500                                         Fax: (305) 445-2505
   Miami, Florida 33131                               Email: arivero@riveromestre.com
   vel@rochefreedman.com                              Email: arolnick@riveromestre.com
                                                      Email: amcgovern@riveromestre.com

   Kyle W. Roche, Esq.                                Email: zmarkoe@riveromestre.com
   Admitted Pro Hac Vice                              Email: receptionist@riveromestre.com
   ROCHE FREEDMAN LLP
   185 Wythe Avenue F2                                By: s/ Andres Rivero
   Brooklyn, New York 11249                           ANDRES RIVERO
   kyle@rochefreedman.com                             Florida Bar No. 613819
                                                      JORGE MESTRE
                                                      Florida Bar No. ___________
                                                      AMANDA MCGOVERN
                                                      Florida Bar No. 964263
                                                      ZAHARAH MARKOE
                                                      Florida Bar No. 504734




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Case 9:18-cv-80176-BB Document 284 Entered on FLSD Docket 09/17/2019 Page 3 of 3



                                  CERTIFICATE OF SERVICE

         I certify that on September 17, 2019, I electronically filed this document with the Clerk of

  the Court using CM/ECF. I also certify that this document is being served today on all counsel of

  record by transmission of Notices of Electronic Filing generated by CM/ECF or by U.S. Mail.




                                                              /s/ Andres Rivero_______
                                                              ANDRES RIVERO
                                                              Florida Bar No. 613819




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