SANDLER v. CALCAGNI et al

Filing 121

MOTION to Extend Time April 24, 2008 to Reply to Booksurge's Memorandum Opposing Plaintiff's Motion for Partial Summary Judgment by SHANA SANDLERResponses due by 4/29/2008. (KUBETZ, BERNARD)

SANDLER v. CALCAGNI et al Doc. 121 UNITED STATES DISTRICT COURT DISTRICT OF MAINE SHANA SANDLER, Plaintiff v. ) ) ) ) ) ) ) ) ) ) ) ) Case No. 1:07-cv-00029 MIA CALCAGNI et al, Defendants PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO REPLY TO BOOKSURGE'S MEMORANDUM OPPOSING PLAINTIFF'S MOTION FOR PARTIAL SUMMARY JUDGMENT, WITH INCORPORATED MEMORANDUM OF LAW Plaintiff Shana Sandler hereby moves for an extension of time within which to reply to the Memorandum Opposing Plaintiff's Motion for Partial Summary Judgment filed by Defendant Booksurge, LLC. Plaintiff's response is currently due on April 14, 2008, and Plaintiff requests a ten-day extension from that date within which to submit its reply. Plaintiff's counsel has been focused on responding to the Motion for Summary Judgment filed by Defendants Booksurge and Peter Mars, which response is also due on April 14, 2008, and has recently been out of the country on vacation. Therefore, Plaintiff's counsel requires additional time to gather the information necessary to reply to the opposing memorandum. Defendants' counsel, William Druary and Bruce Mallonee have indicated that they consent to the granting of this Motion. Counsel for Defendant Booksurge has not yet responded to the inquiry from Plaintiff's counsel. Dockets.Justia.com WHEREFORE, Plaintiff moves for a ten-day extension to and including April 24, 2008, to reply to the Memorandum Opposing Plaintiff's Motion for Partial Summary Judgment. Dated at Bangor, Maine, this 8th day of April, 2008. PLAINTIFF, Shana Sandler, BY____/s/ Bernard J. Kubetz Bernard J. Kubetz, Esq. Eaton Peabody 80 Exchange Street P. O. Box 1210 Bangor, Maine 04402-1210 (207) 947-0111 bkubetz@eatonpeabody.com 2 CERTIFICATE OF SERVICE I, Bernard J. Kubetz, hereby certify that on April 8, 2008, I electronically filed the foregoing Motion for Extension of Time to Reply to the Memorandum Opposing Plaintiff's Motion for Partial Summary Judgment with the Clerk of the United States District Court using the CM/ECF system, which will send notification of such filing to the following: Bruce Mallonee, Esq. Rudman & Winchell, LLC P. O. Box 1401 Bangor, Maine 04402-1401 bmallonee@rudman-winchell.com Steven P. Wright, Esq. Kirkpatrick & Lockhart Preston Gates Ellis LLP State Street Financial Center One Lincoln Street Boston, Massachusetts 02111-2950 steven.wright@klgates.com Matthew J. Segal, Esq. Stephen A. Smith, Esq. Kirkpatrick & Lockhart Preston Gates Ellis LLP 925 Fourth Avenue, Suite 2900 Seattle, Washington 98104-1158 matthew.segal@klgates.com J. William Druary, Jr., Esq. Marden, Dubord, Bernier & Stevens P. O. Box 708 Waterville, Maine 04903-0708 bdruary@mardendubord.com Harold J. Friedman, Esq. Friedman, Gaythwaite Wolf & Leavitt P. O. Box 4726 Portland, Maine 04112-4726 hfriedman@FGWL-law.com /s/ Bernard J. Kubetz_________ Bernard J. Kubetz 3