Counter-Plaintiffs1 have already agreed that discovery is appropriate for the Declaratory Judgment/PI Motion—the only question before the Court is the scope of such discovery. CounterPlaintiffs have requested significant discovery from Plaintiffs, and Plaintiffs agreed to respond to all discovery requested by Counter-Plaintiffs, including additional requests for discovery beyond that included in the Court’s July 15, 2019 Scheduling Order (Dkt. 53). Indeed, Plaintiffs are working hard to provide responses to the broad discovery sought by Counter-Plaintiffs. Yet despite a mutual exchange of discovery,2 Counter-Plaintiffs insist that they can selectively use the PSLRA stay in a way that it was never intended—as both a sword to allow it to marshal evidence in its sole possession in favor of its position3 and as a shield to prevent Plaintiffs from being able to access key evidence relating to disputed fact issues.