Case 0:15-cv-62334-RLR Document 48 Entered on FLSD Docket 09/26/2016 Page 1 of 15

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA
Case No.: 15-cv-62334-ROSENBERG-BRANNON

TAURIGA SCIENCES, INC.,

A Florida Corporation,
Plaintiff,
v.
COWAN, GUNTESKI & CO., P.A.,
A Foreign Corporation; DONALD
COWAN, an Individual; and WILLIAM
MEYLER, an Individual,
Defendants.
______________________________________/
DEFENDANTS MOTION TO RESCHEDULE TRIAL TERM
Defendants Cowan, Gunteski & Co., P.A., Donald Cowan, and William Melyer
(collectively Defendants), by counsel, respectfully move to reschedule the January 23, 2017
Trial Term to permit sufficient time to conduct discovery and prepare for trial in this complex
commercial matter in which Plaintiff seeks a multi-million dollar recovery.
INTRODUCTION
This case is not yet at issue. Defendants, citizens of New Jersey, lack minimum contacts
with the State of Florida. The Defendants motion to dismiss for lack of personal jurisdiction is
pending. The Defendants also challenge venue under 28 U.S. C. 1406 on the basis that there is
no dispute that the requirements of 28 U.S.C 1391 are not satisfied (the Plaintiff has presented no
argument to the contrary).

Even assuming discovery has properly commenced pending

resolution of these threshold issues, discovery only commenced two months ago, on July 21,
2016, when the parties conducted their Rule 26(f) conference.

19206515.1

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For virtually all of the first month following the parties Rule 26(f) conference, the
Plaintiff led the Defendants to believe that it had consented to the transfer of this case to the
District of New Jersey, and therefore the Defendants delayed commencing discovery due to the
pending transfer. The Plaintiff unexpectedly withdrew its agreement to transfer consensually in
late August and instead filed a motion to compel discovery responses, triggering the setting of a
scheduling conference and discovery hearing.
At the telephonic scheduling conference and discovery hearing conducted on September
8, 2016, Magistrate Judge Brannon set the discovery cut-off for October 7, 2016, just 29 days
thereafter. Magistrate Judge Brannon also set the dispositive motions deadline for October 21,
2016. Magistrate Judge Brannon acknowledged that the discovery cutoff did not permit time
even to hand-deliver a set of written discovery, and recommended that if either party felt more
time was necessary for discovery, that such party should file a motion directed to Your Honor to
re-set the trial term, followed by a motion directed to him to revise the schedule.
The discovery schedule, set at the first substantive conference in this matter, was not
established until 29 days before the current close of discovery, insufficient time for the
Defendants to propound any written discovery, and insufficient time to schedule and conduct all
but one of the several third-party depositions which are necessary in this case. The deadline for
dispositive motions and motions in limine falls four (4) days before the deadline for the parties to
disclose expert witnesses. As this case is likely to require significant expert testimony, this
deadline effectively precludes any motions with respect to expert witnesses.
Defendants submit that this motion is not a result of the Defendants failure to diligently
pursue discovery. The absence of adequate time to conduct discovery the Defendants find
themselves in is largely driven by the Plaintiffs improper filing of this action prior to completing

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contractually required mediation, a stay of the action requested ex parte by the Plaintiff prior to
the Defendants appearance, and a first motion to reschedule the trial term filed by the Plaintiff
prior to the Defendants appearance, and without notice to the Defendants (contrary to the
certificate of service). The foregoing scheduling matters were compounded by the Plaintiffs
agreement, almost immediately following the Rule 26(f) conference, to transfer the case to the
District of New Jersey. It was not until the end of August, shortly before the scheduling
conference, that Plaintiff reneged on its agreement to transfer the case. The result of the
foregoing factors is that the Defendants have, through no fault of their own, been placed in the
untenable position of having to defend a complex and significant commercial case without any
meaningful opportunity to conduct discovery.
FACTUAL AND PROCEDURAL BACKGROUND
1.

Plaintiff filed this case on November 4, 2015 (Docket No. 1).

Prior to the

commencement of suit Plaintiffs counsel was specifically informed of the pre-suit mediation
clause in Plaintiffs engagement agreement with Defendant Cowan, Gunteski & Co., but
nevertheless proceeded to file suit. The Complaint (at 7) falsely alleged that all conditions
precedent to the filing of this action, if any, have been performed or otherwise waived.
2.

On December 1, 2015, the Court set a November 7, 2016, trial term (Docket No.

3.

The Plaintiff moved to stay the case on December 29, 2015 (Docket No. 14) in

11).

order to permit the parties to conduct a contractually required mediation. Prior to that time,
counsel had agreed to defer service of the summons and complaint until completion of the
mediation.

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4.

The parties mediated the case in February, 2016, in New York City.

The

mediator requested that the Plaintiff produce various documents needed in order to continue the
mediation. The Plaintiff failed to do so.
5.

On April 13, 2016, the Defendants executed waivers of service.

counsel filed the waivers on April 15, 2016, (Docket Nos. 17-19).

Plaintiffs

Based on Rule 4(d),

Defendants Rule 12(b) motions or answers were due June 13, 2016.
6.

On May 9, 2016, the Plaintiff moved to terminate the stay and requested that the

trial term be re-set (Docket No. 20). While the Plaintiffs motion stated that it was served on all
parties, it was never in fact ever served on the Defendants. Contrary to the statements in
Paragraph 5 of the motion, Plaintiffs, not Defendants counsel, in fact filed the waivers of
service, and as a result, the Defendants did not receive a CM/ECF notice of the filing.
7.

On May 10, 2016, the Court entered its Order Setting Status Conference,

Calendar Call, and Trial Date and Order of Reference to Magistrate (Docket No. 22), which
provided that Magistrate Judge Brannon would conduct a Pre-Trial Conference pursuant to Rule
16 of the Federal Rules of Civil Procedure, and further provided that the trial term could be reset by Magistrate Judge Brannon prior to the Pre-Trial Status Conference scheduled for
December 7, 2016, at 9:30 a.m. Defendants do not believe that the Pre-Trial Conference
pursuant to Rule 16 of the Federal Rules of Civil Procedure was ever held. The Defendants
anticipated an opportunity to have input in the ultimate schedule for the case, including trial,
particularly in view of the threshold motions they always intended to file. In its May 10, 2016,
Order, the Court set the current trial term, which begins January 23, 2017.

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8.

On June 13, 2016, Defendants timely filed their Motion to Dismiss Pursuant to

Fed. R. Civ. P. 12(b)(2) and/or to Dismiss or Transfer Venue Pursuant to 28 U.S.C. 1406(a)
(the Motion to Dismiss) (Docket No. 23).
9.

On July 21, 2016, the parties conducted their Rule 26(f) conference within the

time required by Local Rule 16.1(b).

10.

Rule 26(d)(1) provides that discovery may not commence until the parties have

held their Rule 26(f) conference.

11.

The parties exchanged drafts of their Rule 26(f) conference statement between

July 21, 2016, and July 25, 2016, (Defendants provided the final draft, to which Plaintiffs
counsel never responded). Defendants understood that Plaintiffs counsel would file the Rule
26(f) conference statement, however it appears it was never filed.
12.

On July 25, 2016, Plaintiff served its first request for documents on Defendants.

13.

The Defendants most recent draft of the 26(f) conference statement, recognizing

the complexity of this matter and the need for significant discovery, proposed that all discovery
be completed by July 22, 2017, with Plaintiffs experts reports due on May 21, 2017,
Defendants reports on June 30th and an August 5, 2017 cut-off date for potentially dispositive
motions. Plaintiffs counsel never objected to the Defendants proposed dates.1
14.

Plaintiffs position during the 26(f) conference was consistent with its previous

pronouncements about the length of time this matter would require. In numerous public filings
with the United States Securities and Exchange Commission Tauriga stated that [t]he lawsuit
was expected by the Company and its counsel to take up to 18 months to complete from the date
it was filed (November 4, 2015).

Plaintiffs previous draft of the 26(f) conference statement proposed earlier dates than those included in
Defendants most recent draft of the 26(f) conference statement.

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15.

Counsel held a telephone conference on Friday, July 29, 2016, at 2:30 p.m.

During the conference Plaintiffs counsel stated that Plaintiff consented to the transfer of venue
to the District of New Jersey. The parties agreed that Plaintiffs counsel would draft and
circulate the transfer stipulation while Defendants counsel would draft the proposed
confidentiality agreement that was also discussed during the call.

Thereafter the parties

exchanged drafts of a stipulation transferring this case to the District of New Jersey.2
16.

Defendants were led to believe that Plaintiff had agreed to transfer this case,

thereby mooting the Motion to Dismiss or the need to proceed with discovery in this court. On
August 17, 2016, Plaintiffs counsel emailed his legal assistant, copying Defendants counsel,
instructing her to file the consent order containing Defendants revisions thereby transferring
venue to the United States District Court for the District of New Jersey, where the Defendants
reside and where the operative acts and omissions are alleged to have occurred.
17.

Shortly after his August 17, 2016 email confirming the agreement to transfer

venue, matters began to devolve as Plaintiffs counsel attached additional conditions to the
transfer.
18.

After August 17, 2016, the parties continued to discuss the transfer, however by

August 23, 2016, Plaintiffs counsel had gone silent with respect to the transfer.
19.

As of August 23, 2016, Defendants had not commenced discovery, in part in

reliance on the impending agreed transfer, and in part out of concern that doing so could be
deemed a waiver of Defendants challenges to personal jurisdiction and venue asserted in the
Motion to Dismiss. Although the case had technically been pending for over nine months
2

Defendants incorporate herein by reference their Memorandum in Opposition to Plaintiffs Motion to Compel
Discovery and Renewed Motion for Protective Order (Docket No. 38) (the Response) and specifically paragraphs
12-41 of the Response and all exhibits to the Response incorporated into those paragraphs which more fully detail
the communications between Plaintiffs and Defendants counsel that induced Defendants to hold off on discovery
pending the anticipated transfer to the District of New Jersey.

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(inclusive of the Plaintiffs requested stay of over four months due to Plaintiffs premature filing
of suit), Defendants had not sought to move the trial term. By all indications, this case was not
going to proceed in this Court, the Defendants understood that a new schedule would issue once
the case was transferred to the District of New Jersey. The Defendants reasonably anticipated
that if the case were for any reason not transferred, either by agreement or court order, or
dismissed, Magistrate Judge Brannon would then hold a scheduling conference at which time he
could adjust the trial term and issue a schedule based on the parties Rule 26(f) conference
report.
20.

On August 29, 2016, Plaintiff filed motions to compel discovery (Docket Nos. 35,

21.

On August 30, 2016, the Court set a telephonic hearing for September 8, 2016, to

36).

address the motions to compel discovery and to consider scheduling matters.

22.

During the September 8, 2016, telephonic conference, Magistrate Judge Brannon

imposed a discovery cutoff of October 7, 2016, and a dispositive motions deadline of October
21, 2016.
23.

The foregoing deadlines, set at the initial substantive conference and while

motions contesting both personal jurisdiction and venue remain pending, preclude the conducting
of appropriate discovery. Federal Rules of Civil Procedure 33 and 34 give the responding party
30 days to respond to interrogatories and/or requests for production. Even if Defendants had
served these discovery requests by hand delivery immediately after the September 8, 2016,
hearing, they would not have been due until October 8, 2016, after the discovery cutoff.

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24.

Additionally, the Courts September 9, 2016, order (Docket No. 41) sets October

21, 2016, as the deadline for filing all pretrial motions, including summary judgment motions,
Daubert motions, and motions in limine. The default deadline for parties to disclose expert
witnesses pursuant to Fed. R. Civ. P. 26(a)(2)(D) is 90 days prior to the trial date, or October 25,
2016. Under the current scheduling order, it will be impossible for the parties to challenge or
limit any of the proposed expert testimony prior to trial because the deadline for doing so expires
before the first deadline for parties to disclose experts.

In addition, the current schedule

precludes any opportunity for the fact discovery needed to properly prepare this case for trial.
DEFENDANTS ANTICIPATED SCOPE OF DISCOVERY
25.

This accounting malpractice action arises out of the assertion of the Public

Company Accounting Oversight Board that defendant Cowan Gunteski was not independent
with respect to its audit of Taurigas financial statements for its fiscal year ended March 31,
2014, resulting in Taurigas being de-listed from the OTCQB Exchange in favor of the OTC
Pink Sheets.
26.

Tauriga is an early development stage company that has operated in a variety of

unestablished, speculative business ventures. As of March 31, 2015, the last twelve month
period for which results have been publically reported, Tauriga had generated less than $100,000
in revenue while sustaining an accumulated deficit of slight in excess of $49mm.

While

Taurigas complaint does not identify specific damages, based on discussions, numerous press
releases and its public filings, the Plaintiff is claiming that it sustained significant out of pocket
losses (last reported at in excess of $1mm in an August 31, 2016, press release), as well as
substantial lost opportunity costs in purported ongoing efforts to enter into new business ventures
and raise new speculative capital.

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27.

In view of these assertions, on September 19, 2016, Defendants served their

written discovery requests on Plaintiff. Among other materials Defendants sought information
and documents concerning:

the out of pocket damages the Plaintiff is claiming as a result of its

delisting;

the transactions or proposed transactions the Plaintiff is claiming were

adversely impacted following its delisting from the OTCQB Exchange;

the transactions the Plaintiff has been able to complete since the delisting;

the Plaintiffs efforts to mitigate its alleged damages;

the information the Plaintiff has provided to and received from thirdparties concerning the litigation, including those from who the Plaintiff
has requested funding for the litigation; and

the documents concerning the Plaintiffs prior, unsuccessful business

relationships and the dates and reasons for the repeated write offs of
various intangible assets.

28.

Once Defendants have been provided this information, they will be in a position

to determine which of the Plaintiffs current, former or prospective business contacts need to be
deposed, as well as the professionals working or who have worked for the Plaintiff who need to
be examined. In their Rule 26(f) Conference the parties, recognizing the need for significant
non-party discovery, agreed to a maximum of fifteen (15) depositions per side, with the right to
seek leave of court for additional depositions if needed.

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LEGAL STANDARD
29.

Defendants Motion to Reschedule Trial Term (the Motion) is brought pursuant

to Federal Rule of Civil Procedure 7(b) and Local Rule 7.6 which permit a party to seek a
continuance of a trial date. The Court of Appeals for the Eleventh Circuit considers: 1) the
extent of movants diligence in its efforts to ready its defense prior to the date set for trial, 2) the
extent to which granting the continuance would have inconvenienced the court and the nonmovant, including the witnesses, and 3) the extent to which movant might have suffered harm as
a result of the district courts denial, in deciding whether a district courts denial of a motion to
continue constitutes an abuse of discretion. Perlman v. Delisfort-Theodule, 541 Fed. Appx. 846,
849 (11th Cir. 2012). The affidavit of Ronald S. Herzog is submitted as Exhibit A in support of
the Motion in compliance with the Local Rule and is fully incorporated herein.
ARGUMENT
30.

The primary ground for extending the trial date is to allow the parties sufficient

time to conduct discovery, while affording the Court sufficient time to determine whether
Plaintiff properly brought this action in this court.3 As recently as late July, Plaintiffs counsel
recognized that it would take until the end of July, 2017 to complete discovery. Had Plaintiffs
counsel filed the Rule 26 report with Plaintiffs proposed discovery schedule, Magistrate Judge
Brannon would presumably have set a discovery schedule comporting with the complexities of
the case and its current status (delayed through no fault of the Defendants, in significant part due

As noted in the Motion to Dismiss, the complaint lacks any allegation which would support either personal
jurisdiction or venue in this diversity action. The sole allegation concerning either is that the New Jersey based
Defendants knew that Tauriga was a Florida corporation and, thus, would subject itself to venue [sic] in Florida in
the event of controversy or litigation (complaint, Docket Entry 1, at paragraphs 3-5).
Plaintiffs opposition sought to confer jurisdiction not on any acts of the Defendants, but rather the residence of a
third-party, the independent accounting firm of Cherry Bekaert, LLP, that provided valuation services in connection
with the 2014 audit, services which are not relevant to the claims asserted in the Complaint. Plaintiffs opposition
never addressed Defendants motion asserting improper venue.

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to the months long stay in view of Taurigas mediation obligation which obligation Plaintiff
ignored when it commenced this action), rather than imposing a schedule that effectively
prevents the Defendants from conducting any discovery.
31.

Relying on Plaintiffs representations that it had agreed to transfer the case to the

District of New Jersey, Defendants initially refrained from initiating discovery, and did not
pursue the Plaintiffs failure to file the Rule 26(f) conference report. The Defendants served
their initial written discovery on September 19th. Prior to serving their discovery and preparing
this motion, the Defendants first complied with Magistrate Brannons directive to respond to
Plaintiffs First Requests for Production by September 15th (over 17,000 pages of documents
were produced by that date) and coordinating the deposition date of defendant Meyler.
32.

Plaintiffs suspect conduct provides additional cause to continue the current trial

date to a later date. To begin with, the action should never have been commenced in November,
2015 since counsel had specifically been informed of the pre-suit mediation requirement in
Plaintiffs engagement letter.

At the earliest, this condition precedent to the proper

commencement of suit was only satisfied until April, 2016, when the parties completed their
unsuccessful mediation and the Defendants agreed to waive service of process. Defendants then
timely moved to dismiss. In addition, Plaintiffs May 9, 2016 motion to re-set the trial term
falsely stated that it was served on all parties. Finally, despite instructing his office to file the
agreed upon stipulation transferring this action to New Jersey, Plaintiffs counsel never did so.
33.

Defendants anticipate that discovery will require 150 180 days to complete. As

previously noted, once the Plaintiff produces its documents and identifies the third-parties with
relevant information sought through Defendants written discovery, the Defendants will require
time to coordinate and schedule several third-party depositions, and propound third-party

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documentary discovery concerning Plaintiffs various damage claims.

Anticipating the

possibility of confidentiality objections from third-parties, during the Rule 26(f) conference, in
order to minimize delay during the discovery process the Defendants requested a limited
confidentiality order that would have restricted the use of information obtained in discovery,
including information from non-parties. Plaintiff agreed to this at the Rule 26(f) conference, but
later reneged on this agreement as well. Defendants submit that the discovery schedule will need
to include sufficient time to permit the resolution of any third-party confidentiality concerns
created by the absence of a confidentiality agreement.
34.

Discovery in this case will require the requested amount of time even with the

parties working diligently and purposefully due to the large number of documents sought from
the Plaintiff and third-parties, and due to the several various claimed components of its damages.
Defending the Plaintiffs damage claims will require numerous third-party fact witnesses that
will need to be deposed. Even had discovery commenced on July 21, 2016, the date the parties
held the Rule 26(f) conference, there is no reasonable way that discovery in this action could
properly be conducted prior to October 7, 2016.
35.

Applying the Perlman factors weighs in favor of the Court granting the Motion

and continuing the trial date. First, Defendants have diligently involved themselves in discovery
in this case since the time it became apparent that the Plaintiff would not consummate its prior
agreement consenting to the transfer of venue. Defendants have mediated, waived service, filed
the Motion to Dismiss without seeking an extension, afforded Plaintiff an extension for its
opposition, engaged in numerous discussions with Plaintiff to transfer the case, and filed motions

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for protective orders as well as making a substantial document production in very short order.
Each of these independent actions is an example of the Defendants efforts to further this case
towards resolution through a trial on the merits in the appropriate court.
36.

Secondly, the request for a continuance, at this time, does not prejudice the Court

or the Plaintiff. The trial term is currently set for January 23, 2017, four (4) months away.
Granting a continuance at this juncture and four months in advance of the trial date should not
inconvenience Plaintiff or its witnesses, especially given Plaintiffs repeated public filings that
the lawsuit was expected by the Company and its counsel to take 18 months to complete from
the date it was filed (November 4, 2015). In addition, in their draft 26(f) conference statement
Defendants proposed that discovery not be completed until July 22, 2017.4
37.

Finally, the harm to Defendants in the event the continuance is not granted will be

great. It will preclude Defendants from conducting any meaningful discovery in this case,
discovery that is necessary to defend against the claims of substantial damages by a company
which has consistently lost vast amounts of money. The information concerning the Plaintiffs
damages claims is exclusively within the Plaintiffs possession, and the possession of numerous
third-parties with whom Plaintiff has or is presently working, none of whom is presently known
to Defendants. The Defendants are entitled to depose such witnesses as are necessary to provide
a proper defense, and are entitled to other forms of discovery that will are also necessary in this
case.

Plaintiff did not object to Defendants most recent draft of the 26(f) conference statement. Plaintiff proposed that
the discovery completion deadline be April 7, 2017 in its draft of the 26(f) conference statement.

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CONCLUSION
The potential harm in not extending the trial date to allow Defendants a meaningful
opportunity to conduct discovery far outweighs any potential harm a continuance would cause
the Plaintiff, or we respectfully submit, any inconvenience to the Court. As Plaintiff previously
recognized, other than whatever improper benefit may accrue to the Plaintiff as a result of the
Defendants inability to conduct any discovery, the Plaintiff will also benefit from a continued
trial date and additional time to conduct discovery.

For the reasons articulated herein,

Defendants respectfully request the entry of an Order continuing the trial date that is currently set
for January 23, 2017, to July 24, 2017, or such later date as would be set at the Courts
convenience if this matter will remain in this Court following a ruling on Defendants Motion to
Dismiss, and granting such other and further relief as is appropriate under the circumstances.
Dated: September 26, 2016
Respectfully submitted,
LECLAIRRYAN, a Professional Corporation
/s/ Andrew L. Cole
Andrew L. Cole (Fla. Bar No. 0187496)
andrew.cole@leclairryan.com
180 Admiral Cochran Drive, Suite 520
Annapolis, Maryland 21401
P. (410) 224-3000
F. (410) 224-0098
and
/s/ Ronald S. Herzog
Ronald S. Herzog (admitted pro hac vice)
Ronald.Herzog@leclairryan.com
885 Third Avenue, 16th Floor
New York, NY 10022
Tel: (212) 697-6555
Fax: (212) 986-3509
Attorneys for Defendant Cowan, Gunteski &
Co., P.A., Donald Cowan and William Meyler

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CERTIFICATE REGARDING CONFERENCE OF COUNSEL

I HEREBY CERTIFY, that on September 9, 2016, at approximately 2:30 p.m., I
conducted a telephonic meeting with Kraig Weiss, counsel for the Plaintiff, during which we
discussed in good faith the trail date continuance sought by the Defendants herein, and that on
September 26, 2016, at approximately 3:45 p.m., I conducted a second telephonic meeting with
Kraig Weiss, counsel for the Plaintiff, during which we again discussed the matter. The parties
were unable to reach agreement on the subject matter of the foregoing motion.

/s/ Andrew L. Cole

Andrew L. Cole

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 26th day of September, 2016, a copy of the foregoing
paper or pleading, together with all exhibits and attachments, was served electronically via the
Courts CM/ECF System, upon all registered users who have entered an appearance in this
action, including:
Paul K. Silverberg, Esq.
Kraig S. Weiss, Esq.
SILVERBERG & WEISS, P.A.
1290 Weston Road, Suite 218
Weston, Florida 33326
psilverberg@pkslegal.com
kweiss@pkslegal.com
notices@pkslegal.com
Mmiller@pkslegal.com
npaolino@pkslegal.com
tgordon@pkslegal.com
/s/ Andrew L. Cole
Andrew L. Cole

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