Kardonick v. JP Morgan Chase & Co. et al

Filing 41

Unopposed MOTION for Leave to File Excess Pages of Response to Motion to Intervene by David Kardonick. (Mussman, Louis) Modified on 3/28/2011 (ls).

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Kardonick v. JP Morgan Chase & Co. et al Doc. 41 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION DAVID KARDONICK, individually and on behalf of all others similarly situated and the general public, Plaintiff, vs. JURY TRIAL DEMANDED JPMORGAN CHASE & CO. and CHASE BANK USA, N.A., Defendants. _________________________________________ / PLAINTIFF'S UNOPPOSED MOTION TO FILE LEGAL MEMORANDUM IN EXCESS OF 20 PAGES IN RESPONSE TO MOTION TO INTERVENE Pursuant to Local Rule 7.1(c)(2), Plaintiff DAVID KARDONICK hereby requests CASE NO.: 1:10-cv-23235/HOEVELER CLASS ACTION COMPLAINT permission to file a legal memorandum in opposition to the Motion to Intervene of up to 30 pages in length. In support of this motion, Plaintiff hereby states as follows: 1. On March 9, the objectors filed their Motion to Intervene, which was accompanied by a 20 page memorandum. The Movants' memorandum asks this Court to (a) permit them to intervene in this action, (b) name Movants' counsel as new Class counsel, and (c) vacate the preliminary approval order. 2. The Motion to Intervene covers a wide range of factual and legal questions. In order to address this range of issues, Plaintiff respectfully requests leave to file a legal memorandum that will not exceed 30 pages in length. 3. Plaintiff will use its best efforts to keep the memorandum as short as possible while still addressing the necessary range of factual and legal issues in a manner that it believes will be helpful to the Court. Dockets.Justia.com 4. This motion is made in the interest of justice, not to delay the proceedings, and will not prejudice any party. Certification Pursuant to Local Rule 7.1 5. The undersigned counsel certifies that Counsel for the Movants (Kevin Landau, Esq.) and counsel for the Defendants (Andrew Soukup, Esq.) do not oppose this motion Respectfully Submitted, Dated: March 28, 2011 Ku & Mussman, P.A. /s/ Brian Ku Brian Ku (FL Bar # 610461) Louis Mussman (FL Bar # 597155) 12550 Biscayne Blvd., Suite 406 Miami, Florida 33181 Tel: (305) 891-1322 Fax: (305) 891-4512 brian@kumussman.com Richard M. Golomb Ruben Honik Kenneth J. Grunfeld GOLOMB & HONIK, P.C. 1515 Market Street, Suite 1100 Philadelphia, PA 19102 Tel: (215) 985-9177 kgrunfeld@golombhonik.com Allan Kanner (LA Bar #20580) Conlee S. Whiteley (LA Bar #22678) M. Ryan Casey (LA Bar #30192) KANNER & WHITELEY, L.L.C. 701 Camp Street New Orleans, Louisiana 70130 Tel: (504) 524 -5777 c.whiteley@kanner-law.com ATTORNEYS FOR PLAINTIFF CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 28th day of March, 2011, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record or pro se parties in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing. /s/ Brian Ku Brian Ku (FL Bar # 610461) UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION DAVID KARDONICK, individually and on behalf of all others similarly situated and the general public, Plaintiff, vs. JURY TRIAL DEMANDED JPMORGAN CHASE & CO. and CHASE BANK USA, N.A., Defendants. _________________________________________ / ORDER GRANTING PLAINTIFF'S UNOPPOSED MOTION TO FILE LEGAL MEMORANDUM IN EXCESS OF 20 PAGES IN RESPONSE TO MOTION TO INTERVENE THIS CAUSE, having come before the Court upon Plaintiff's Unopposed Motion to File Legal Memorandum in Excess of 20 Pages in Response to Motion to Intervene, and the Court being fully advised in the premises. IT IS HEREBY ORDERED AND ADJUDGED that said Motion is GRANTED. DONE AND ORDERED in Chambers this ____day ______________of, 2011. CASE NO.: 1:10-cv-23235/HOEVELER CLASS ACTION COMPLAINT ____________________________________ United States District Judge cc: All counsel of record

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