Steinbuch v. Cutler et al
MOTION for Extension of Time to File Response/Reply as to 4 Amended Complaint by Hyperion Books, Disney Publishing Worldwide. (Deere, Beth) (MODIFICATION: The original document was submitted in error; the correct document was added as an attachment on 6/30/2006.) (thd)
Steinbuch v. Cutler et al
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UNITED STATES DISTRICT COURT FOR THE EATSERN DISTRICT OF ARKANSAS ROBERT STIENBUCH v. Case No.: 4-06 CV0000 620WRW PLAINTIFF
JESSICA CUTLER AND HYPERION BOOKS AND DISNEY PUBLISHING WORLDWIDE AND HOME BOX OFFICE AND TIME WARNER
MOTION FOR EXTENSION OF TIME TO ANSWER OR OTHERWISE RESPOND BY SEPARATE DEFENDANTS HYPERION BOOKS AND DISNEY PUBLISHING WORLDWIDE Separate defendants Hyperion Books and Disney Publishing Worldwide (collectively "Separate Defendants"), for their unopposed motion for extension of time, state: 1. Plaintiff served his First Amended Complaint on Separate Defendants on June 23, 2006. 2. The answers or other response pleadings of Separate Defendants are due on July 13, 2006. 3. Separate Defendants seek an extension of time to file their answers or other responses to the Plaintiff's Amended Complaint up to and including Friday, August 18, 2006. 4. Counsel for Plaintiff has indicated that Plaintiff does not oppose such an extension of time. Exhibit A
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5. This motion is not made for delay or for any other improper purpose, and good cause exists for extending the time to answer or otherwise respond. 6. By moving for an extension of time, Separate Defendants are not waiving any of their defenses; they specifically reserve the right to raise all available defenses in their responsive pleadings, including, but not limited to, lack of personal jurisdiction. 7. Under United States District Court for the Eastern District of Arkansas Local Rule 7.2(d) there is no brief required in support of this motion. WHEREFORE, Separate Defendants Hyperion Books and Disney Publishing Worldwide respectfully request that this Court grant this motion for extension of time up to and including Friday, August 18, 2006 to file their answers or responses to plaintiff's complaint. Respectfully submitted, WILLIAMS & ANDERSON PLC 111 Center Street Twenty-Second Floor Little Rock, Arkansas 72201 (501) 372-0800 (501) 372-6453 (facsimile) By: /s/ Beth Deere Philip S. Anderson, Ark. Bar # 60001 Jess L. Askew, Ark. Bar # 86005 Beth M. Deere, Ark. Bar #86050 Clayborne S. Stone, Ark. Bar # 2003102
Attorneys for Separate Defendants Hyperion Books & Disney Publishing Worldwide.
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CERTIFICATE OF SERVICE I, Beth Deere, certify that on this 29th day of June, 2006, I have served a copy of the foregoing on the Plaintiff by delivering a copy of same to his attorney, by first-class U.S. Mail, postage prepaid, at the following address: Jonathan Rosen 1200 Gulf Blvd. Clearwater, FL 33767 (908) 759-1116 Attorney for plaintiff __/s/ Beth Deere ___________________ Beth Deere
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EXHIBIT A -----Original Message----From: Satyendra, Indira [mailto:Indira.Satyendra@abc.com] Sent: Tuesday, June 27, 2006 11:17 AM To: Beth M. Deere Subject: FW: Steinbuch v. Cutler et al., 4:06-cv-00620, E.D. Arkansas / -----Original Message----From: Jonathan Rosen [mailto:firstname.lastname@example.org] Sent: Monday, June 26, 2006 10:20 PM To: Satyendra, Indira Cc: email@example.com Subject: Re: Steinbuch v. Cutler et al., 4:06-cv-00620, E.D. Arkansas Ms. Satyendra: Please disregard my last e-mail as I mis-referenced the parties. This message confirms my agreement to an extension of time for defendants Hyperion Books and Disney Publishing Worldwide to respond to the complaint until Friday, August 18, 2006. Please send all written correspondence, filings and/or documents to my New Jersey office. The address is: Jonathan Rosen, Esquire 1645 Lamington Road Bedminster, NJ 07921 Jonathan Rosen 908.759.1116
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