Republican National Committee v. Virgin Islands Board of Elections
1 IN THE DISTRICT COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN REPUBLICAN NATIONAL COMMITTEE; REPUBLICAN PARTY OF THE VIRGIN ISLANDS Plaintiffs, vs. VIRGIN ISLANDS BOARD OF ELECTION; CAROLINE F. FAWKES, in her official capacity as SUPERVISOR OF ELECTIONS SYSTEM, VIRGIN ISLANDS, Defendants. Case No. 3:22-cv-00049-RAM-RM JOINT MOTION TO EXTEND TIME TO COMPLETE DISCOVERY Plaintiffs and Defendants jointly request for the Court’s leave to complete currently outstanding discovery past March 31, 2023. In support of this motion, the parties state as follows: 1. Under this Court’s scheduling order, fact discovery closes on March 31, 2023. See Doc. 43, at 1. 2. On February 24, 2023, Plaintiffs served a set of requests for admissions, requests for production, and interrogatories. Defendants’ responses are currently due on March 27, 2023. 3. Plaintiffs’ counsel also advised Defendants’ counsel that Plaintiffs would notice three depositions before the close of fact discovery. And on March 15, 2023, Plaintiffs formally noticed those depositions. 4. …
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1 IN THE DISTRICT COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN REPUBLICAN NATIONAL COMMITTEE; REPUBLICAN PARTY OF THE VIRGIN ISLANDS Plaintiffs, vs. VIRGIN ISLANDS BOARD OF ELECTION; CAROLINE F. FAWKES, in her official capacity as SUPERVISOR OF ELECTIONS SYSTEM, VIRGIN ISLANDS, Defendants. Case No. 3:22-cv-00049-RAM-RM JOINT MOTION TO EXTEND TIME TO COMPLETE DISCOVERY Plaintiffs and Defendants jointly request for the Court’s leave to complete currently outstanding discovery past March 31, 2023. In support of this motion, the parties state as follows: 1. Under this Court’s scheduling order, fact discovery closes on March 31, 2023. See Doc. 43, at 1. 2. On February 24, 2023, Plaintiffs served a set of requests for admissions, requests for production, and interrogatories. Defendants’ responses are currently due on March 27, 2023. 3. Plaintiffs’ counsel also advised Defendants’ counsel that Plaintiffs would notice three depositions before the close of fact discovery. And on March 15, 2023, Plaintiffs formally noticed those depositions. 4. Consistent with the representations made during the status conference on February 7, 2023, Defendants seek an additional 30 days to prepare their responses and production. Because Defendants’ responses and production would be due on April 26, 2023, the parties seek this Court’s permission to complete discovery past the current March 31 discovery deadline. Case: 3:22-cv-00049-RAM-RM Document #: 47 Filed: 03/16/23 Page 1 of 3 2 5. Given this request for an extension, the parties also request permission for Plaintiffs to conduct depositions within a reasonable time after reviewing Defendants’ discovery responses and production. 6. This modest extension of discovery deadlines will not unduly prejudice any party because both parties consent to such relief and jointly file this motion. Critically, this extension will not delay any further proceedings before the Court. Under the scheduling order, Plaintiffs’ dispositive motion is not due until June 30, 2023. Plaintiffs will have an ample amount of time to prepare a dispositive motion even if the depositions take place in May. 7. For the foregoing reasons, and other good cause found, the parties jointly request that the Court allow Defendants to respond to Plaintiffs’ discovery requests by April 26, 2023, and allow Plaintiffs to conduct the depositions within a reasonable time after April 26, 2023. Dated: March 16, 2023 /s/ Andrew L. Capdeville Andrew L. Capdeville, Esq (V.I. Bar No. 206) 8000 Nisky Shopping Center, Suite 201 P.O. Box 6576 St. Thomas, VI 00804-6576 Tel: (340) 774-7784 Fax: (340) 774-2737 Respectfully submitted, /s/ Tyler R. Green Tyler R. Green (pro hac vice) CONSOVOY MCCARTHY PLLC 222 S. Main Street, 5th Fl. Salt Lake City, UT 84101 (703) 243-9423 tyler@consovoymccarthy.com Cameron T. Norris (pro hac vice) Frank H. Chang (pro hac vice) CONSOVOY MCCARTHY PLLC 1600 Wilson Blvd., Ste. 700 Arlington, VA 22209 (703) 243-9423 cam@consovoymccarthy.com frank@consovoymccarthy.com Counsel for Plaintiffs Republican National Committee and Republican Party of the Virgin Islands Case: 3:22-cv-00049-RAM-RM Document #: 47 Filed: 03/16/23 Page 2 of 3 3 Dated: March 16, 2023 /s/ Christopher M. Timmons Christopher M. Timmons, Esq (V.I. Bar No. R.2147) Assistant Attorney General 213 Estate La Reine, RR1 Box 6151 Kingshill, VI 00851 (340) 773-0295 christopher.timmons@doj.vi.gov Counsel for Defendants Case: 3:22-cv-00049-RAM-RM Document #: 47 Filed: 03/16/23 Page 3 of 3