Dec. 6th, 6th's Motion to Dismiss hearing"IBC further claims that, without expedited discovery, it cannot identify what Defendants have taken, how Defendants have used what was taken, and precisely which actions may be necessary fully to enjoin the illegal conduct. Yet, IBC has access to its own records and correspondences and IBC is aware of its own trade secrets. A basic review of the claims in this case show that the requested discovery directly relates to IBCs general allegations. Compare Complaint with IBCs Motion and Supp.. Also, unlike Caperton, there is no threat that property will be sold or concealed. Despite IBCs assertions, neither Mr. Schrider nor Ucore have access to the Pilot Plant as they do not possess keys to the facility. IBC holds the keys. Due to the broad scope of the discovery requested and IBCs failure to validate the expedited discovery, the only conceivable purpose behind the request is to conduct nearly all discovery under the guise of a preliminary injunction. Thus, the Court should deny IBCs Motion as an attempt to circumvent the discovery process". -------- And this, is why he's now trying this "emergency discovery", all the while a dam Dorsey laundry list of what procedures they continue to ignore ------ " Despite IBCs implication to the contrary, the October 31 scheduling conference was to set a date for the preliminary injunction hearing, not to establish discovery deadlines or to issue a scheduling order pursuant to Rule 16. Moreover, the motion to dismiss this case will be heard on December 16, which could dispose of the entire case".------- and that's also exactly what will be requested in good ol NS and Utah federal is my bet. https://cdn.pacermonitor.com/pdfserver/YXN3API/117162708/IBC_Advanced_Technologies_v_6th_Wave_Innovations_et_al__utdce-19-00826__0037.0.pdf