Heartland Recreational Vehicles LLC v. Forest River Inc

Filing 139

Joint MOTION for Extension of Time to File Response/Reply as to 134 MOTION for Partial Summary Judgment Against Heartland for Unfair Competition, 130 MOTION for Summary Judgment by Counter Claimant Forest River Inc. (Fountain, Ryan)

Heartland Recreational Vehicles LLC v. Forest River Inc Doc. 139 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 ) ) ) JURY DEMAND JOINT REQUEST FOR EXTENSION OF TIME TO RESPOND TO SUMMARY JUDGMENT MOTIONS DE#130 AND DE#134 The parties jointly request that they be granted an extension of time of five days in which to respond respectively to the two pending summary judgment motions, DE#130 and DE#134. The responses were originally both due by December 3, 2010 and would be due by December 8, 2010 by this motion. The request has been made because of the number of issues involved in the two motions and to accommodate a third party's scheduling needs for deposition on December 2, the transcript of which is expected to be used in connection with at least one of the responses. A proposed form of order is forwarded to chambers concurrently herewith. December 3, 2010 Respectfully submitted, s/Ryan M. Fountain Ryan M. Fountain (Atty. #8544-71) 420 Lincoln Way West Mishawaka, Indiana 46544 1 s/David P. Irmscher David P. Irmscher (Atty. #15026-02) 111 East Wayne, Suite 800 Fort Wayne, Indiana 46802 Dockets.Justia.com Tel.: 574-258-9296 Fax: 574-256-5137 RyanFountain@aol.com Attorney for Defendant Forest River, Inc. Tel.: 260.424.8000 Fax: 260.460.1700 David.irmscher@bakerd.com Attorney for Plaintiff Heartland Recreational Vehicles, LLC 2