Filing 63

ENTERED IN ERROR.....Consent MOTION for Extension of Time to Oppose Plaintiffs' Motion to Compel by PUBLIC.RESOURCE.ORG, INC. (Attachments: #1 Text of Proposed Order)(Bridges, Andrew) Modified on 12/24/2014 (rdj).

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  IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA AMERICAN SOCIETY FOR TESTING AND MATERIALS d/b/a ASTM INTERNATIONAL; NATIONAL FIRE PROTECTION ASSOCIATION, INC.; and AMERICAN SOCIETY OF HEATING, REFRIGERATING, AND AIR CONDITIONING ENGINEERS, Case No. 1:13-cv-01215-TSC-DAR CONSENT MOTION FOR EXTENSION OF TIME FOR DEFENDANT’S OPPOSITION TO PLAINTIFFS’ MOTION TO COMPEL (DKT. NO. 27) Plaintiffs/Counterdefendants, v. PUBLIC.RESOURCE.ORG, INC., Defendant/Counterclaimant. Defendant-Counterclaimant Public.Resource.Org , Inc. (“Public Resource”), respectfully moves this Court pursuant to Fed. R. Civ. P. 6(b) and LCvR 7 for an extension of time until January 5, 2015 to oppose Plaintiffs’ Motion to Compel Discovery, Privilege Log, and Further Initial Disclosures (Dkt. No. 27). Before filing of this motion, Defendant’s counsel conferred with Plaintiffs’ counsel via email on December 19, 2014 and December 23, 2014, pursuant to LCvR 7(m). Plaintiffs consent to an extension to January 5, 2015. Plaintiffs filed its Motion to Compel Discovery, Privilege Log, and Further Initial Disclosures on December 15, 2014. Under the local rules, Public Resource’s opposition would be due on a day when its counsel’s offices would be closed for the holidays. Counsel for defendant thus asked Plaintiffs to consent to an extension of time to oppose the motion on December 19, 2014. On December 23, 2014, Jonathan Hudis, counsel for Plaintiffs, agreed to an     extension of the opposition due date to January 5, 2015. Fed. R. Civ. P. 6(b)(1) provides that the court may extend a filing deadline for good cause. Good cause exists here because: (i) all parties consent to the extension, (ii) the extension is a short one due to a holiday office closure, and (iii) the extension does not prejudice any party or affect any court hearing dates or case management deadlines. ACCORDINGLY, Public Resource respectfully requests that the Court grant it an extension until January 5, 2015 to oppose Plaintiffs’ Motion to Compel Discovery, Privilege Log, and Further Initial Disclosures. Dated: December 24, 2014 Respectfully submitted, /s/ Andrew P. Bridges Andrew P. Bridges (admitted) FENWICK & WEST LLP 555 California Street, 12th Floor San Francisco, CA 94104 Telephone: (415) 875-2300 Facsimile: (415) 281-1350 David Halperin (D.C. Bar No. 426078) 1530 P Street NW Washington, DC 20005 Telephone: (202) 905-3434 Corynne McSherry (pro hac vice) Mitchell L. Stoltz (D.C. Bar No. 978149) ELECTRONIC FRONTIER FOUNDATION 815 Eddy Street San Francisco, CA 94109 Telephone: (415) 436-9333 Facsimile: (415) 436-9993 Attorneys for Defendant/Counterclaimant Public.Resource.Org, Inc.    

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