Cambridge University Press et al v. Patton et al

Filing 413

Consent MOTION for Extension of Time to File Response Briefing on Proposed Post Trial Findings of Fact and Conclusions of Law re: 409 Proposed Findings of Fact, 412 Proposed Findings of Fact, 411 Proposed Order, 392 Order on Motion for Extension of Time, 410 Proposed Findings of Fact, by J. L. Albert, Mark P. Becker, Kenneth R. Bernard, Jr, Larry R. Ellis, Rutledge A. Griffin, Jr, Robert F. Hatcher, C. Thomas Hopkins, Jr, W. Mansfield Jennings, Jr, James R. Jolly, Donald M. Leebern, Jr, William NeSmith, Jr, Risa Palm, Doreen Stiles Poitevint, Willis J. Potts, Jr, Neil L. Pruitt, Jr, Wanda Yancey Rodwell, Nancy Seamans, Kessel Stelling, Jr, Benjamin J. Tarbutton, III, Richard L. Tucker, Larry Walker, Philip A. Wilheit, Sr. (Schaetzel, Stephen)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION

CAMBRIDGE UNIVERSITY PRESS,
et al.,
Plaintiffs,

Civil Action No.
1:08-CV-1425-ODE

-vs.MARK P. BECKER, in his official
capacity as Georgia State University
President, et al.,
Defendants.
CONSENT MOTION FOR A SHORT EXTENSION OF TIME TO FILE
RESPONSE BRIEFING ON PROPOSED POST TRIAL FINDINGS OF FACT
AND CONCLUSIONS OF LAW
Now come the above-named Defendants and notify the Court of the Parties’
agreement to a short extension of time, from July 29, 2011 until 6 pm Eastern
Standard Time, Saturday, July 30, 2011, to file responsive briefing on the Parties’
proposed post trial findings of fact and conclusions of law in the above-referenced
matter, and move the court to grant this consent motion for the same.
At the conclusion of the trial, the Court set July 15, 2011 as the due date for
filing of the post-trial papers and one week after for filing responsive papers. On
July 11, 2011, this Court granted an extension for filing post-trial papers to July 22,

2011, thereby extending the deadline for responsive briefing to July 29, 2011. (Dkt.
392.)
Defendants’ response brief electronic file has become corrupted and cannot be
edited. Defendants are informed by technical support that it will take several hours
to correct the problem (i.e., “clean” the document). Defendants have contacted
counsel for Plaintiffs regarding this problem, and Defendants are authorized to
represent that Plaintiffs have consented to extending the time for both sides to file
responsive papers until 6 pm Eastern Standard Time, Saturday, July 30, 2011.
It is respectfully submitted that good cause has been shown for the motion to
extend the time for filing. A proposed order is attached for the convenience of the
Court.

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Respectfully submitted this 29th day of July, 2011.
SAMUEL S. OLENS
Georgia Bar No. 551540
Attorney General
R. O. LERER
Georgia Bar No. 446962
Deputy Attorney General
DENISE E. WHITING-PACK
Georgia Bar No. 558559
Senior Assistant Attorney General
MARY JO VOLKERT
Georgia Bar No. 728755
Assistant Attorney General
KING & SPALDING LLP
/s/ Stephen M. Schaetzel
Stephen M. Schaetzel
Georgia Bar No. 628653
John W. Harbin
Georgia Bar No. 324130
Natasha H. Moffitt
Georgia Bar No. 367468
Mary Katherine Bates
Georgia Bar No. 384250
KING & SPALDING LLP
1180 Peachtree Street, N.E.
Atlanta, GA 30309
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Anthony B. Askew
Georgia Bar No. 025300
Special Assistant Attorney General
McKeon, Meunier, Carlin & Curfman, LLC
817 W. Peachtree Street NW, Suite 900
Atlanta, GA 30308
Phone: [phone]
Fax: [phone]
[e-mail]
Katrina M. Quicker
Georgia Bar No. 590859
BALLARD SPAHR LLP
999 Peachtree Street, Suite 1000
Atlanta, GA 30309-3915
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Defendants

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CERTIFICATE OF COMPLIANCE
I hereby certify, pursuant to L.R. 5.1B and 7.1D of the Northern District of
Georgia, that the foregoing CONSENT MOTION FOR A SHORT EXTENSION OF
TIME TO FILE RESPONSE BRIEFING ON PROPOSED POST TRIAL
FINDINGS OF FACT AND CONCLUSIONS OF LAW complies with the font and
point selections approved by the Court in L.R. 5.1B. The foregoing pleading was
prepared on a computer using 14-point Times New Roman font.

/s/ Stephen M. Schaetzel______
Stephen M. Schaetzel
Georgia Bar No. 628653

UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION

CAMBRIDGE UNIVERSITY PRESS,
et al.,
Civil Action File
No.1:08-CV-1425-ODE

Plaintiffs,
-vs.MARK P. BECKER, in his official
capacity as Georgia State University
President, et al.,
Defendants.

[PROPOSED] CONSENT ORDER
For good cause shown, it is hereby ORDERED that the time for all parties to
file response briefing to proposed post-trial findings of fact and conclusions of law is
extended until 6 pm Eastern Standard Time, Saturday, July 30, 2011.
SO ORDERED the ____ day of July, 2011.
_____________________________
The Honorable Orinda D. Evans
United States District Judge

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION

CAMBRIDGE UNIVERSITY PRESS,
et al.,
Plaintiffs,

Civil Action No.
1:08-CV-1425-ODE

-vs.MARK P. BECKER, in his official
capacity as Georgia State University
President, et al.,
Defendants.

CERTIFICATE OF SERVICE
The undersigned hereby certifies that, on this 29th day of July, 2011, I have
electronically filed the foregoing CONSENT MOTION FOR A SHORT
EXTENSION OF TIME TO FILE RESPONSE BRIEFING ON PROPOSED POST
TRIAL FINDINGS OF FACT AND CONCLUSIONS OF LAW with the Clerk of
the Court using the CM/ECF system, which will automatically send e-mail
notification of such filing to the following attorneys of record:

Edward B. Krugman
[e-mail]
Georgia Bar No. 429927
Corey F. Hirokawa
[e-mail]
Georgia Bar No. 357087
John H. Rains IV
Georgia Bar No. 556052
BONDURANT, MIXSON &
ELMORE, LLP
1201 West Peachtree Street NW
Suite 3900
Atlanta, GA 30309
Telephone: [phone]
Facsimile: [phone]

R. Bruce Rich
Jonathan Bloom
Randi Singer
Todd D. Larson
WEIL, GOTSHAL & MANGES LLP
767 Fifth Avenue
New York, New York 10153
Telephone: [phone]
Facsimile: [phone]

/s/ Stephen M. Schaetzel________
Stephen M. Schaetzel
Georgia Bar No. 628653

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