Code Revision Commission et al v. Public.Resource.Org, Inc.

Filing 26

Joint MOTION for Extension of Time to File Proposed Consolidated Pretrial Order by Code Revision Commission, State of Georgia. (Askew, Anthony)

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
CODE REVISION COMMISSION on
behalf of and for the benefit of THE
GENERAL ASSEMBLY OF
GEORGIA, and THE STATE OF
GEORGIA,
Plaintiff,

CIVIL ACTION NO.

v.

1:15-CV-02594-MHC

PUBLIC.RESOURCE.ORG, INC.
Defendant.
JOINT MOTION FOR EXTENSION OF TIME TO FILE
PROPOSED CONSOLIDATED PRETRIAL ORDER

Plaintiff and Counterclaim-Defendant the Code Revision Commission, on
behalf of and for the benefit of the General Assembly of Georgia, and the State of
Georgia (“Commission”), and Defendant and Counterclaim-Plaintiff
Public.Resource.Org, Inc. (“Public Resource”) jointly move for the Court to extend
the deadline for filing the proposed consolidated pretrial order to thirty (30) days
after the Court rules on the parties’ summary judgment motions. Currently, LR
16.4 requires filing of the proposed order by April 18, 2016, yet the deadline for
filing summary judgment motions under this Court’s Scheduling Order (Dkt. 013)

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is not until May 17, 2016. Both parties intend to file motions for summary
judgment on or before the deadline of May 17, 2016.
Respectfully submitted, this 14th day of April, 2016.
/s/Anthony B. Askew/
Anthony B. Askew (G.A. Bar: 025300)
Lisa C. Pavento (G.A. Bar: 246698)
Warren J. Thomas (G.A. Bar: 164714)
Meunier Carlin & Curfman LLC
999 Peachtree Street, NE, Suite 1300
Atlanta, Georgia 30309
Phone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]

/s/Elizabeth H. Rader (by express
permission)/
Elizabeth H. Rader (pro hac vice)
ALSTON & BIRD LLP
950 F Street, NW
Washington, DC 20004
Telephone: [phone]
Fax: [phone]
[e-mail]
Jason D. Rosenberg
Georgia Bar No. 510855
Sarah Parker LaFantano
ALSTON & BIRD LLP
One Atlantic Center
1201 West Peachtree Street
Atlanta, GA 30309-3424
Telephone [phone]
Fax [phone]
[e-mail]
[e-mail]

Counsel for the Plaintiff, Code Revision
Commission on behalf of and for the
benefit of the General Assembly of
Georgia, and the State of Georgia

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Counsel for the Defendant,
Public.Resource.Org

CERTIFICATE OF COMPLIANCE
I hereby certify that, pursuant to L.R. 5.1C and 7.1D of the Northern District
of Georgia, the foregoing MOTION FOR EXTENSION OF TIME TO
FILE PROPOSED CONSOLIDATED PRETRIAL ORDER complies
with the font and point selections approved by the Court in L.R. 5.1C. The
foregoing pleading was prepared on a computer using 14-point Times New Roman
font.

/s/Anthony B. Askew/
Anthony B. Askew (G.A. Bar: 025300)
Meunier Carlin & Curfman LLC
999 Peachtree Street NE, Suite 1300
Atlanta, Georgia 30309
Telephone: [phone]
Email: [e-mail]

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CERTIFICATE OF SERVICE
I, the undersigned counsel, hereby certify that on April 14, 2016, a true and
correct copy of the foregoing MOTION FOR EXTENSION OF TIME TO
FILE PROPOSED CONSOLIDATED PRETRIAL ORDER was
electronically filed with Clerk of Court using the CM/ECF system which will
automatically send notification of such filing to all attorneys of record.

/s/Anthony B. Askew/
Anthony B. Askew (G.A. Bar: 025300)
Meunier Carlin & Curfman LLC
999 Peachtree Street NE, Suite 1300
Atlanta, Georgia 30309
Telephone: [phone]
Email: [e-mail]

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