Blaszkowski et al v. Mars Inc. et al

Filing 276

NOTICE by All Plaintiffs of Filing Declaration of Catherine J. MacIvor in Support of Plaintiff's Cross-Motion to Strike Portions of the Jurisdictional Defendants' Response (Attachments: # 1 Declaration of Catherine J. MacIvor# 2 Exhibit "A")(MacIvor, Catherine)

Blaszkowski et al v. Mars Inc. et al

Doc. 276 Att. 2

Case 1:07-cv-21221-CMA

Document 276-3

Entered on FLSD Docket 12/12/2007

Page 1 of 1

From: Licko, Carol A. [mailto:[e-mail]] Sent: Friday, November 16, 2007 5:11 PM To: Catherine J. MacIvor Subject: Blasz Catherine: Counsel for all Defendants have conferred today, and reached a consensus position as to your two proposed motions: 1. As to your request for an extension of 4 months for the Court's Nov. 16 deadline to amend pleadings and join parties, Defendants request you include this response in your motion regarding our good faith conferral: "Defendants believe the 4-month extension requested by Plaintiffs to amend pleadings and join parties is excessive under the circumstances, but will not formally oppose this request." 2. As to your motion for leave to amend to file the second amended complaint sent to us in draft form (and modified to reflect those defendants you are voluntarily dismissing for lack of personal jurisdiction), Defendants request you include this response in your motion regarding our good faith conferral: "Defendants will not formally oppose Plaintiffs' motion to amend with the second amended complaint, but will oppose any further amendment. If the Court grants Plaintiffs' motion, Defendants request that the Court also set a briefing schedule allowing Defendants 30 days to serve one consolidated response to the second amended complaint, allowing Plaintiffs 30 days to serve any opposition to Defendants' motion to dismiss, and allowing Defendants 20 days to serve one consolidated any reply." Thank-you.

CAROL LICKO, PARTNER HOGAN & HARTSON LLP Mellon Financial Center, 1111 Brickell Avenue, Suite 1900, Miami, FL 33131 direct +1.305.459.6612 | tel [phone] | fax [phone] [e-mail] | http://www.hhlaw.com

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Exhibit "A"

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