Steinbuch v. Hachette Book Group

Filing 32

MOTION for Extension of Time to File Response/Reply as to 31 MOTION to Amend/Correct by Hachette Book Group (Attachments: # 1 Exhibit 1)(Stone, Clayborne)

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Steinbuch v. Hachette Book Group Doc. 32 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION ROBERT STEINBUCH v. No. 4-08-C V-000456 JLH PLAINTIFF HACHETTE BOOK GROUP DEFENDANT MOTION FOR EXTENSION OF TIME Defendant Hachette Book Group, Inc. ("Hachette"), for its motion for extension of time, states: 1. Plaintiff served Hachette by mail with his motion for leave to amend his complaint on May 8, 2009. 2. 3. 1-lachette's response to that motion is due on or before May 22, 2009. During the time it has to respond, the undersigned attorneys representing Hachette will be unavailable for much of this week and next. 4. Hachette requests an extension of time to answer or otherwise respond to the plaintiff's motion for leave to amend, up to and including Friday, June 5, 2008. 5. Hachette attempted to contact plaintiff on May 11, 12. and 13, 2009 regarding this motion, but plaintiff has not responded to Hachette' s email and telephone messages. See Exhibit 1. WHEREFORE, defendant Hachette Book Group respectfully requests an extension of time up to and including June 5, 2009 in which to respond to plaintiff's motion for leave to amend his complaint. WILLIAMS & ANDERSON PLC Twenty-Second Floor 111 Center Street Little Rock, AR 72201 501.372.0800 cstone ( williamsandersoitcom By: Is! Clayborne S. Stone Philip S. Anderson. Ark. Bar. No. 60001 Clayborne S. Stone, Ark. Bar No. 2003102 AttornevsJr Detèndant Hachette Book Group CERTIFICATE OF SERVICE I hereby certify that on this 13th day of May. 2009. a copy of the foregoing motion was filed via this Court's CM/ECF system and a copy has been served via U.S. Mail and electronic mail upon: Robert Steinbuch, Esquire 6834 Cantrell Road, #222 Little Rock, AR 72207 rohertsteinhuch@ Is! Clayborne S. Stone 7

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