Gainor v. Sidley, Austin, Brow - Document No. 19

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Case 1:06-cv-217481:06-cv-21748-JEM JEM

Document 19

Entered on FLSD Docket 09/08/2006

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO   06-21748 CIV-MARTINEZ/BANDSTR A

MARK MAR KJ J.. GAINOR  

Plaintiff  

SIDLEY, AUSTIN, BROWN & WOOD, LLP,

Defend an t s

DEFENDANT'S AGREED MOTION FOR ENLARGEMENT OF TIME IN WHICH TO REPLY TO PLAINTIFF'S OPPOSITIO N TO DEFENDANT'S MOTION TO DISMISS AND COUNSEL'S CERTIFICATION OF HAVING CONFERRE   Defendant, SIDLEY AUSTIN LLP f/k/a/ SIDLEY AUSTIN BROWN & WOOD LLP' ( Brown & Wood ), b y and through its undersigned counsel   moves this Court for an order enlarging the time in which Brown   Wood must reply to Plaintiff ' s Memoran du dum m of Law in Opposition to

Defend an t ' s Motion to Dismiss Plaintiff   s Complaint The grounds for this motion are as follows    

Plaintiff serv ed

his opposition to Defend ant Brown

Wood ' s Motion to Dismiss o n

August 30, 2006; howeve however, r, it was not receive received d by De Defendant fendant unti untill Septemb September er 5, 2006

2

. Pursuant to S .D

.L . R . 7   1 . C .1, Brown & Wood's reply me memorandum morandum would woul d be due

on Monday, September 11, 2006 3

 

 

. Due to good cause shown below Defendant needs an additional fourteen (14) days

in which to prepare its reply . Aaron May, the attorney principally handling the reply brief, is presently engaged in a review of thousands of documents in response to a subpoena by the Securitie s

' On January 1, 2006, Sidley Austin Brown & Wood LLP changed its name to Sidley Austin LLP  

 

Case 1:06-cv-217481:06-cv-21748-JEM JEM

Document 19

Entered on FLSD Docket 09/08/2006

Page 2 of 3

CASE NO : 06-21748 CIV-MARTINEZBANDSTR A  

and Exchange Commission, the production of which iis s due Septem September ber 15, 2005 . In addition, Mr   May must respond by September 20`h to an amended complaint in another matter involving Brown & Wood, Freuh v . First Union National Bank, Case No. No . 05-445 05-4455, 5, pending in the Circuit Court for f or  

Hillsborough County . Florida . During this same time frame, Mr . May is preparing a summary

judgment judg ment motion in in re UC A irways,e al, Case No . 04-1381 04-13814. 4. pending in the United Unit ed States Bankruptcy Court for the Eastern District of Virginia

 

4 . This motion is thus ma de in good faith and not for the purposes of delay . The requested enla enlargeme rgement nt would make the Defendant Defendant's 's reply due on September September 25, 2006   5

. On September September 5th, B Brown rown & Wood's counsel, Jonathan Altman and Aaron May,

conferred with Plaintiff's Plain tiff's counsel, coun sel, Richard B Benjamin enjamin Wilkes, Wilkes, who graciously au authorized thorized the them m to represent to the Court his agreement with the relief requested in this motion   WHEREFORE, Defendant, Brown & Wood seeks an order enlarging the time in which it must reply to Plaintiff's Opposition to Defendant's Motion to Dismiss Plaintiff's Complaint so as to make that reply due on or before September 25, 2006  

CERTIFICATE OF SERVIC E I HEREBY CERTIFY that a true and correct copy was faxed and mailed this ? of September, 2006, on Richard Richa rd Benjamin Wilkes, Esq . And Richard W . Candelora, Esq .,

d' ay

 

Case 1:06-cv-217481:06-cv-21748-JEM JEM

Document 19

Entered on FLSD Docket 09/08/2006

Page 3 of 3

CASE NO : 06-21748 CIV-MARTINEZBANDSTRA CIV-MARTINEZBANDSTRA  

Richard

enjamin Wilkes , P .A ., 600 South Magnolia Avenue, Suite 200   Ta mpa   Flo Flori ri da 33606 Respectfully submi tt ed

 

PODHURST ORSECK, P .A 25 West Flagler Street   Suite 800  

T e l . 305   358-2800 / Fax 305   358-23 8 h~LLII U O DUIIUCb .LUIJ I

By  

~ { • r ~ - = r, r, °- L

c

KATHERINE W . FELL

F la   B ar No . 11477   And

MUNGER, TOLLES & OLSON, LLP Jonathan E . Altman, Altman, Esq Aaron M . May, Esq  

 

355 South Grand Avenue, 35`h Floor

Los Angeles, CA 90071-156 0

  613) 683-9100/Fax 613) 683-513 6 Attorneys for Defendant Sidley Austin, LLP

 

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