Doe 1 et al v. Ciolli et al

Filing 64

Joint MOTION for Extension of Time until September 10, 2008 file and serve Opposition to Mariner's Motion To Dismiss 59 MOTION to Dismiss Pursuant to Rule 12(B)(6) or in the alternative for failure to prosecute by Doe 1, Doe 2. (Ramani, Ashok) Modified on 10/6/2008 to remove special character text (Grady, B.).

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Doe 1 et al v. Ciolli et al Doc. 64 UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT DOE I and DOE II, Plaintiffs, v. Unknown Individuals, Defendants. Case No. 3:07CV00909 (CFD) August 29, 2008 JOINT MOTION FOR EXTENSION OF TIME TO FILE AND SERVE OPPOSITION TO DEFENDANT A HORSE WALKS INTO A BAR'S, A.K.A., RYAN MARINER'S, MOTION TO DISMISS PURSUANT TO RULE 12(B)(6) OR IN THE ALTERNATIVE TO DISMISS FOR FAILURE TO PROSECUTE PURSUANT TO RULES 4 AND 41 Plaintiffs DOE I and DOE II and Defendant A Horse Walks Into A Bar, a.k.a. Ryan Mariner ("Mariner), move the Court to allow Plaintiffs an additional seven (7) calendar days, until September 10, 2008, to file and serve their Opposition to Mariner's Motion to Dismiss Pursuant to Rule 12(b)(6) or in the Alternative to Dismiss for Failure to Prosecute Pursuant to Rules 4 and 41 ("Mariner's Motion to Dismiss"). As per Local Rule 7, Plaintiffs' Opposition is due on September 3, 2008. Mariner agrees to extending the time for Plaintiffs to file and serve their Opposition to September 10, 2008. This Court has not previously granted Plaintiffs an extension of time to file and serve their Opposition to Mariner's Motion to Dismiss. The basis of this motion is as follows: 1. The parties are currently in discussions to resolve Plaintiffs' claims against Mariner. The parties need additional time to complete their discussions before the date on which Plaintiffs would need to file their Opposition to Mariner's Motion to Dismiss. Thus, in the interest of judicial economy and to permit sufficient time for the discussions to proceed, the parties seek to extend the due date for Plaintiffs' Opposition to Mariner's Motion to Dismiss. 424406.01 1 Dockets.Justia.com Dated: September 2, 2008 PLAINTIFFS DOE I AND DOE II By: /s/ Ashok Ramani Mark Lemley (pro hac vice) Ashok Ramani (pro hac vice) KEKER & VAN NEST, LLP 710 Sansome Street San Francisco, CA 94111 Telephone: (415) 391-5400 Facsimile: (415) 397-7188 Email: MLemley@kvn.com ARamani@kvn.com David N. Rosen David Rosen & Associates PC 400 Orange Street New Haven, CT 06511 Telephone: (203) 787-3513 Facsimile: (203) 789-1605 Email: drosen@davidrosenlaw.com Dated: September 2, 2008 DEFENDANT A HORSE WALKS INTO A BAR A.K.A. RYAN MARINER By: __/s/W. Anthony Collins______________ W. Anthony Collins Jr. (pro hac vice) Hoppe, Collins & Ojeda, LLC 1827 Powers Ferry Road SE Building 7, Suite 350 Atlanta, GA 30339 Phone: (678) 370-0084 Fax: (404) 745-8245 Email: collins@hcolegal.com 424406.01 2

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