IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DIVISION OF ILLINOIS 

EASTERN DIVISION 

MUSIC DEALERS, LLC, ) 

 ) 

 Plaintiff/Counter-Defendant, ) Case No. 12 CV 712 

 ) 

v. ) Judge Sharon J. Coleman 

 ) 

SIERRA BRAVO CORPORATION, ) Magistrate Judge Rowland 

 ) 

Defendant/Counter-Plaintiff. ) 

 

AGREED MOTION TO MODIFY DISCOVERY SCHEDULE

 Plaintiff/Counter-Defendant, Music Dealers, LLC (“MDL”), by and through its attorneys, 

Elvis Gonzalez, Ltd., moves the Court pursuant to Federal Rule of Civil Procedure 6 to enter an 

Order, extending the time for the completion of written fact discovery, and to modify the 

discovery schedule previously entered. In support thereof, MDL states as follows: 

1. MDL instituted this action in the Circuit Court of Cook County on December 13, 

2011, asserting causes of action arising out of a software application designed for it by 

Defendant/Counter-Plaintiff, Sierra Bravo Corporation (“SBC”). On Febraury 1, 2012, SBC 

filed a Notice of Removal. 

 2. On November 19, 2012, the Court entered a scheduling order, requiring, inter 

alia, written fact discovery to be completed by March 11, 2013, and oral fact discovery to be 

completed by June 17, 2013 (“the Scheduling Order”). 

 3. The parties have each propounded and responded to written discovery requests, 

and each party has made its initial production of documents. However, the parties require 

additional time within which to negotiate the terms of a protective order, and to produce 

additional, confidential documents. In addition, additional time may be required to resolve 

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various objections raised in the parties’ discovery responses, which is not anticipated by the 

current March 11, 2013 deadline for the completion of written fact discovery. As such, GTM 

requests that the current written fact discovery completion date be extended by thirty days to 

allow the parties to complete their document productions, and to resolve their differences or file 

motions to compel if they are unable to otherwise come to an accord, and that the other deadlines 

of the Scheduling Order be adjusted accordingly. 

 4. The undersigned has consulted with counsel for SBC, who does not object to the 

instant motion. This is MDL’s first request for an extension or modification of discovery 

deadlines. 

WHEREFORE, Plaintiff, Music Dealeres, LLC, respectfully prays that the Court enter an 

Order, extending the current deadline for the completion of written fact discovery and oral fact 

discovery by thirty days, extending the deadline for the filing of dispositive motions by thirty 

days, and for such other and further relief as the Court deems just and equitable. 

Respectfully Submitted, 

MUSIC DEALERS, LLC 

 /s/ Elvis D. Gonzalez_________________ 

 By: Its Attorney 

Elvis D. Gonzalez (ARDC NO. 6280115) 

ELVIS GONZALEZ, LTD. 

Three First National Plaza 

70 West Madison Street, Suite 1515 

Chicago, Illinois 60602 

312-558-9779 

egonzalez@elvisgonzalezltd.com 

405641.1-11270.00100

Case: 1:12-cv-00712 Document #: 23 Filed: 03/06/13 Page 2 of 2 PageID #:266