Heartland Recreational Vehicles LLC v. Forest River Inc

Filing 119

Joint MOTION for Extension of Time to Complete Discovery by Plaintiff Heartland Recreational Vehicles LLC. (Irmscher, David)

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF INDIANA SOUTH BEND DIVISION HEARTLAND RECREATIONAL VEHICLES, LLC Plaintiff, vs. FOREST RIVER, INC. Defendant. ) ) ) ) ) ) ) ) ) ) Case No. 3:08-CV-490 AS CAN JOINT MOTION FOR EXTENSION OF DEADLINES Heartland Recreational Vehicles, LLC ("Heartland") and Forest River, Inc. ("Forest River") hereby jointly move to extend multiple deadlines in the above-captioned case. The parties are diligently working and cooperating to complete discovery in this matter. However, as the parties cautiously predicted at the March 24, 2010 pre-trial conference, scheduling and administrative difficulties have occurred, thus creating the need to extend the deadline for completion of discovery. The parties believe that an extension of approximately 60 days will be sufficient to allow for the completion of their desired discovery. An extension of the deadline for discovery will also lead to a need to extend the deadlines for the filing of supplemental expert reports and the filing of dispositive motions. Therefore, Heartland and Forest River jointly and respectfully request that the Court enter an order resetting the above-noted deadlines for the following dates: (1) (2) (3) Deadline for completion of discovery: August 2, 2010; Deadline for the filing of supplemental expert reports, if needed: July 23, 2010; Deadline for the filing of dispositive motions: August 17, 2010. Respectfully submitted, BAKER & DANIELS LLP By: /s David P. Irmscher David P. Irmscher (#15026-02) Abigail M. Butler (#22295-02) Peter A. Meyer (#27968-53) 111 East Wayne, Suite 800 Fort Wayne, Indiana 46802 Tel: 260.424.8000 Fax: 260.460.1700 david.irmscher@bakerd.com abigail.butler@bakerd.com ATTORNEYS FOR PLAINTIFF, HEARTLAND RECREATIONAL VEHICLES, LLC By: /s Ryan M. Fountain Ryan M. Fountain (8444-71) 420 Lincoln Way West Mishawaka, Indiana 46544 Tel: 574.258-9296 Fax: 574.256.5137 RyanFountain@aol.com ATTORNEY FOR DEFENDANT, FOREST RIVER, INC. BDDB01 6189405v1 2 CERTIFICATE OF SERVICE The undersigned counsel for plaintiff Heartland Recreational Vehicles, LLC, hereby certifies that a copy of the foregoing was served upon the following parties, this 3rd day of June, 2010 by operation of the Court's electronic filing system: Ryan M. Fountain 420 Lincoln Way West Mishawaka, Indiana 46544-1902 /s/ David P. Irmscher David P. Irmscher BDDB01 6189405v1 3