Heartland Recreational Vehicles LLC v. Forest River Inc

Filing 63

Second MOTION for Extension of Time to File Response/Reply as to 57 MOTION for Protective Order Quashing Subpoenas to Non-Parties by Defendant Forest River Inc. (Fountain, Ryan)

Heartland Recreational Vehicles LLC v. Forest River Inc Doc. 63 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 FOREST RIVER'S SECOND UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO HEARTLAND'S MOTION FOR PROTECTIVE ORDER QUASHING SUBPOENAS TO NON-PARTIES Pursuant to Local Rule 6.1(b), Forest River respectfully requests a second one day extension of time in which to submit its response to Heartland's Motion (docket #57 in this case) due to continued and unexpected personal obligations of Plaintiff's counsel. That response was initially due Friday, October 16, 2009, then was extended to be due today, and now would be due on Tuesday, October 20, 2009, with this extension. The undersigned counsel spoke with David Irmscher, Heartland's lead counsel of record, today concerning this request and was informed that Heartland does not oppose this request. A proposed form of order has been forwarded to chambers herewith. Dated: October 19, 2009 Respectfully submitted, s/Ryan M. Fountain ___________________________ Ryan M. Fountain (#8544-71) 1 Dockets.Justia.com 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 October 19, 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