Canterra And Avpro, Inc.: Case Study

COMES NOW Canterra Energy Corp. (“Canterra”), and Avpro, Inc., (“Avpro”) by and through their undersigned counsel, and files this Consent Motion to Extend Time to respond to 50NL’s Motion To Enforce Subpoena and Compel Production of Documents By Non-Party Avpro, Inc. pursuant to Md. Rule 1-204, and in support thereof states as follows:
1. This discovery dispute arises from an action pending in the District Court of Oklahoma County, Oklahoma, involving the contemplated—but ultimately unconsummated—sale of an aircraft.
2. Avpro served as Canterra’s broker/agent during negotiations for the aircraft.
3. Avpro’s principal offices are located in Annapolis, Maryland.
4. Avpro is a non-party to the underlying action pending in Oklahoma.
5. On September 23, 2016, 50NL, LLC (“50NL”) filed a request for a subpoena duces tecum seeking discovery from Avpro under the authority of the Maryland Uniform Interstate Depositions and Discovery Act. Md. Code (2008, 2016 suppl.) § 9-400 et seq. of the Courts and Judicial Proceedings Article (“CJP”).
6.
A dispute currently exists over the scope of information discoverable from Avpro.
7. On November 15, 2016, 50NL filed a Motion To Enforce Subpoena and Compel Production of Documents By Non-Party Avpro, Inc.
8. Pursuant to Md. Rule 2-311(b), Canterra, Avpro, and any other party with standing the challenge 50NL’s motion to compel has until November 30, 2016, to oppose their motion.
9. On November 29, 2016, Canterra executed a retainer agreement with the undersigned local counsel for Canterra to oppose 50NL’s Motion To Enforce Subpoena and Compel Production of Documents By Non-Party Avpro,