Heartland Recreational Vehicles LLC v. Forest River Inc

Filing 46

Joint MOTION for Extension of Time to Amend 41 Rule 16 Preliminary Pretrial Conference,, by Counter Claimant Forest River Inc. (Fountain, Ryan)

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Heartland Recreational Vehicles LLC v. Forest River Inc Doc. 46 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 AS- CAN ) ) ) JURY DEMAND JOINT MOTION TO AMEND SCHEDULING ORDER The parties respectfully request an extension of time until July 6, 2009, in which to amend the pleadings without leave of the Court. The May 4 Scheduling Order previously indicated that due date to be June 4, 2009. The reason for this extension is that the parties have as yet been unable to conducted discovery which is expected to indicate whether or not such amendment is appropriate. A proposed form of Order has been sent to chambers herewith. The undersigned is authorized to file this motion on behalf of both parties. Dated: June 4, 2009 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. 1 Dockets.Justia.com Certificate of Service I certify that on June 4, 2009, 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