Heartland Recreational Vehicles LLC v. Forest River Inc

Filing 109

Consent MOTION for Extension of Time to File Response/Reply as to 102 Response to Motion, by Counter Claimant Forest River Inc. (Fountain, Ryan)

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UNITED STATES DISTRICT COURT Northern District of Indiana South Bend Division HEARTLAND RECREATIONAL VEHICLES, LLC, Plaintiff, v. FOREST RIVER, INC., Defendant. ) ) ) ) CASE NO.:3:08-cv-490 TLS- CAN ) ) ) JURY DEMAND FOREST RIVER'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO REPLY TO HEARTLAND'S RESPONSE TO FOREST RIVER'S SECOND MOTION TO COMPEL DOCUMENT PRODUCTION Forest River, Inc., requests a one day extension of time in which to reply to "Heartland's Response to Forest River's Second Motion to Compel Document Production" docket #102 in this case. That Response was filed and served on March 15, 2010, and a Reply would be due on March 25, 2010. With this extension of time, the Reply would be due on March 26, 2010. The reason for the request is that the undersigned counsel's office has experienced as yet unresolved difficulties today with its document scanning equipment needed to create the electronic copies of the exhibits to be used in the Reply. It is expected that the problems will either be solved tomorrow or the scans will be created using a commercial service. The undersigned counsel contacted David Irmscher, Heartland's counsel at approximately 1:35 p.m. today, and Mr. Irmscher stated he had no objection to this extension of time. A proposed form of Order has been sent to chambers herewith. 1 Dated: March 25, 2010 Respectfully submitted, s/Ryan M. Fountain ___________________________ Ryan M. Fountain (#8544-71) RyanFountain@aol.com 420 Lincoln Way West Mishawaka, Indiana 46544 Telephone: (574) 258-9296 Telecopy: (574) 256-5137 Attorney for Defendant Forest River, Inc. Certificate of Service I certify that on March 25, 2010, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF system, which sent notification of such filing to all of the parties through at least the following counsel of record: David P. Irmscher Abigail M. Butler david.irmscher@bakerd.com abidgail.bulter@bakerd.com s/Ryan M. Fountain _______________________ Ryan M. Fountain Attorney for Defendant Forest River, Inc. 2