Kardonick v. JP Morgan Chase & Co. et al

Filing 462

MOTION for Extension of Time to File Response/Reply as to 456 Defendant's MOTION for Order to Show Cause and Supporting Memorandum of Law, 460 Order on Motion for Extension of Time, Order on Motion for Leave to File Excess Pages by JP Morgan Chase & Co.. (Attachments: # 1 Text of Proposed Order)(Campbell, Dennis)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION
Case No. 1:1O-cv-23235IHOEVELER

DAVID KARDONICK. JOHN DAVID, and
MICHAEL CLEMINS, individually and on
behalf of all others similarly situated and the
general public.
Plaintiffs,
V.

JPMORGAN CHASE & CO. and CHASE
BANK USA, N.A.
Defendants.

CHASE’S MOTION FOR EXTENSION OF TIME TO FILE
A REPLY 1’vIEMORANDUM

Robert D. Wick
Andrew Soukup
COVINGTON & BURLING LLP
Attorneys for Defendants
1201 Pennsylvania Ave. N.W.
Washington. D.C. 20004
Telephone: [phone]
Facsimile: [phone]

Dennis M. Campbell
CAMPBELL LAW FIRM PLLC
Attorney for Defendants
95 Merrick Way
Suite 514
Coral Gables, Florida 33 134
Telephone: [phone]
Facsimile: [phone]

Defendant Chase Bank USA. N.A. (“Chase”), by and through their undersigned counsel,
hereby moves this Court for a one (1) day extension to file its reply memorandum. In support of
this motion, Chase states as follows:
1. On October 17, 2012, the Court granted Chase’s motion for an extension of time to
file a reply memorandum and motion to exceed the page limit. The Court’s order requires Chase
to file and serve a single consolidated reply memorandum of up to eighteen pages on or before
October 25, 2012. [DE 460].
2. Chase respectfully moves this Court for an additional one-day extension of time that
would permit it to file its reply memorandum on or before October 26, 2012. Chase seeks this
additional extension because of an unexpected matter that required intensive attention from
Chase’s counsel. A one-day extension will also permit Chase to file a shorter and more succin
ct
reply brief.
3. This motion is made in the interest of justice, not to delay the proceedings, and will
not prejudice any party.
WHEREFORE. Chase respectfully moves this Court to grant leave for Chase to file a
reply memorandum on or before October 26, 2012. A proposed order granting this motion
is
attached hereto.

CERTIFICATION
Pursuant to S.D. Fia. L.R. 7.i(a)(3), the undersigned certifies that counsel for Chase has

made reasonable efforts to confer with all parties or non-parties who may be affected by the
relief sought in this motion, by e-mail sent on the morning of October 24, 2012, hut has been
unable to do so.

Dated: October 24, 2012

Respectfully submitted,
Robert D. Wick (admitted pro hac vice)
Andrew Soukup (admitted pro hoc vice)
COVINGTON & BURUNG LLP
Attorneys for Defendants
1201 Pennsylvania Ave. N.W.
Washington D.C. 20004
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
E-mail: [e-mail]
Dennis M. Campbell
CAMPBELL LAW FIRM, PLLC
Attorney for Defendants
95 Merrick Way, Suite 514
Coral Gables, Florida 33134
Telephone: [phone]
Facsimile: [phone]
E-mail:
s/Dennis M. Campbell
Dennis M. Campbell
Florida Bar No. 271527

j

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 24th day of October, 2012, I electronically filed
Chase’s Motion for Extension of Time to File a Reply Brief using the ECF system, which
will
send a notification of such filing to the counsel of record who have entered appearances
in this
action. In addition, I served a true and conect copy of Chase’s Motion for Extension of Time
to
File a Reply Memorandum via e-mail on the following individuals:
Richard M. Golomb, Esq.
Kenneth J. Grunfeld, Esq.
GOLOMB & HONIK, P.C.
1515 Market Street, Suite 1100
Philadelphia, PA 19102
E-mail: [e-mail]
E-mail: [e-mail]

Laura Baughman, Esq.
Thomas M. Sims, Esq.
BARON & BUDD, P.C.
3102 Oak Lawn Ave., Suite 1100
Dallas, TX 75219
E-mail: [e-mail]
E-mail: [e-mail]

J. Burton LeBlanc, IV, Esq.
BARON & BUDD, P.C.
9015 Bluebonnet Boulevard
Baton Rouge, LA 70810
E-mail: [e-mail]

s/Dennis M. Campbell
Dennis M. Campbell

385O37/4524l2

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