Massoli v. Regan Media, et al

Filing 87

Massoli v. Regan Media, et al

Doc. 87

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LAW OFFICES

James L. Blair, #016125 Roger W. Hall, #013727 RENAUD COOK DRURY MESAROS, PA Phelps Dodge Tower One North Central, Suite 900 Phoenix, Arizona 85004-4417 [phone] [e-mail] [e-mail] Attorneys for Plaintiff/Counterdefendants UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA JENNA MASSOLI p/k/a JENNA JAMESON, Plaintiff, v. "REGAN MEDIA," JUDITH REGAN, as an individual, Defendant. REGAN MEDIA, INC., a New York corporation, and JUDITH REGAN, an individual, Defendants/Counterclaimants, v. JENNA MASSOLI, p/k/a JENNA JAMESON, an individual, Plaintiff/Counterdefendant, and JAY GRDINA, an individual, Third-Party Counterdefendant, and DOLCE AMORE, INC., a Colorado corporation, Counterdefendant. CV 05-0854 PHX EHC PLAINTIFF/ COUNTERDEFENDANTS' MOTION FOR EXTENSION OF TIME WITHIN WHICH TO RESPOND TO DEFENDANTS/ COUNTERCLAIMANT REGAN MEDIA'S SECOND MOTION TO COMPEL AND REQUEST FOR SANCTIONS (First Request) (Assigned to the Honorable Earl H. Carroll)

RENAUD COOK DRURY MESAROS
ONE NORTH CENTRAL SUITE 900 PHOENIX, AZ 85004 TELEPHONE [phone] FACSIMILE 602-307-5853

C e 1) (Pagase

2:05-cv-00854-EHC

Document 87

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Dockets.Justia.com

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LAW OFFICES

Pursuant to LRCiv 7.3, Rules of Practice of the United States District Court for the District of Arizona, plaintiff Jenna Massoli, p/k/a Jenna Jameson and counterdefendants John G. "Jay" Grdina and Dolce Amore, Inc. (collectively, "Plaintiffs"), by and through their counsel undersigned, hereby submit this Motion for Extension of Time to Respond to Defendant/Counterclaimant Regan Media's Second Motion to Compel and Request for Sanctions ("Motion to Compel") and requests that this Court extend, until March 24, 2006, the time within which Plaintiffs may file a Response to Defendants/Counterclaimant Regan Media's Second Motion to Compel and Request for Sanctions ("Motion to Compel"), for the reason that on this date both of the firms representing Plaintiffs filed Applications to Withdraw as Counsel ("Application" or "Applications to Withdraw"). As a result, Plaintiffs will need additional time within which to prepare their Response to the Motion to Compel. This Motion is supported by the attached Memorandum of Points and Authorities, as well as the record in this case. MEMORANDUM OF POINTS AND AUTHORITIES On March 7, 2006, the firm of Renaud Cook Drury Mesaros, PA ("RCDM"), current counsel for Plaintiffs, as well as the firm of Lipsitz, Green, Fahringer, Roll, Salisbury & Cambria, LLP current co-counsel for Plaintiffs, both filed Applications to Withdraw. On that same date, the undersigned contacted counsel for Defendants/ Counterclaimants, advised counsel that RCDM would be withdrawing, and requested an extension of time within which Plaintiffs could file a response to the Motion to Compel, due to the pending withdrawal. That request was denied. Accordingly, Plaintiffs ask this Court to grant an approximately two-week extension within which they may file a response to the Motion to Compel, specifically, Plaintiffs request until March 24, 2006. Such an extension will allow Plaintiffs to find new counsel, /// ///

RENAUD COOK DRURY MESAROS
ONE NORTH CENTRAL SUITE 900 PHOENIX, AZ 85004 TELEPHONE [phone] FACSIMILE 602-307-5853

C e 2) (Pagase

2:05-cv-00854-EHC

Document 87

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LAW OFFICES

and allow that counsel to become familiar enough with the case to file an appropriate response to the Motion to Compel. DATED this 9th day of March, 2006. RENAUD COOK DRURY MESAROS, PA

By: /s/ Roger W. Hall James L. Blair Roger W. Hall Phelps Dodge Tower One North Central, Suite 900 Phoenix, AZ 85004-4417 Attorneys for Plaintiff/Counterdefendants The foregoing was filed electronically this 9th day of January, 2006. COPY of the foregoing was hand-delivered to the Honorable Earl H. Carroll on the 10th day of January, 2006. COPY of the foregoing mailed this 9th day of January, 2006, to: David J. Bodney, Esq. Dennis K. Blackhurst, Esq. STEPTOE & JOHNSON, LLP Collier Center 201 East Washington Street, Ste 1600 Phoenix, AZ 85004-2382 Attorneys for Defendants/Counterclaimants /s/ Deborah Robertson

RENAUD COOK DRURY MESAROS
ONE NORTH CENTRAL SUITE 900 PHOENIX, AZ 85004 TELEPHONE [phone] FACSIMILE 602-307-5853

C e 3) (Pagase

2:05-cv-00854-EHC

Document 87

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