NEWDOW et al v. ROBERTS et al

Filing 41

MOTION for Leave to File Dr. Rick Warren's Memorandum of Points and Authorities in Opposition to Motion for Preliminary Injunction by RICK WARREN (Attachments: # 1 Declaration Supporting Motion)(Simms, J) (Additional attachment(s) added on 1/16/2009: # 2 Exhibit Memorandum) (td, ).

NEWDOW et al v. ROBERTS et al

Doc. 41

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ____________________________________ ) MICHAEL NEWDOW, et al., ) ) Plaintiffs, ) v. ) Civil Action No. 08-2248 (RBW) ) HON. JOHN ROBERTS, JR., et al., ) ) Defendants. ) ) ____________________________________)

MOTION OF DEFENDANT DR. RICK WARREN FOR LEAVE TO FILE MEMORANDUM IN OPPOSITION TO PRELIMINARY INJUNCTION Defendant Dr. Rick Warren hereby moves the Court for leave to file a Memorandum in Opposition to Motion for Preliminary Injunction, for good cause as stated in the Declaration of Kevin T. Snider filed in support of this Motion. In short, this lawsuit was filed barely two weeks ago, on December 30, 2008. Rev. Warren retained counsel Pacific Justice Institute on January 14, 2009, at which time counsel became aware of the preliminary injunction hearing the following day and the briefing deadlines which had passed. Counsel believes it is essential for Dr. Warren to have an opportunity

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to defend himself in this hearing, and therefore offers the abbreviated Memorandum of Points and Authorities in Opposition to Plaintiff's Preliminary Injunction Motion, filed herewith. Dated: January 15, 2009 Respectfully submitted, _________/S/_________________ Kevin T. Snider, Chief Counsel PACIFIC JUSTICE INSTITUTE California Bar Number 170988 P.O. Box 276600 9851 Horn Road, Suite 115 Sacramento, CA 95827 Tel. [phone] Fax: [phone] [e-mail] /s/ J. Stephen Simms J. Stephen Simms Simms Showers LLP 20 S. Charles Street, Suite 702 Baltimore, Maryland 21201 Tel. [phone] Fax: [phone] [e-mail] CERTIFICATE OF SERVICE I hereby certify that on January 15, 2009, I served on all parties to this action the foregoing by electronically filing this document through the Court's CM/ECF website.

/s/ J. Stephen Simms

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