Huon v. Breaking Media et al

Filing 205

MOTION by Defendants Breaking Media, Breaking Media, Inc., Breaking Media, LLC, David Lat, John Lerner, David Minkin, Elie Mystal for extension of time to file their reply in support of their motion to dismiss plaintiff's fourth amended complaint - unopposed (Mandell, Steven)

UNITED STATES DISTRICT COURT FOR THE
NORTHERN DISTRICT OF ILLINOIS – EASTERN DIVISION
MEANITH HUON,
Plaintiff,
v.
BREAKING MEDIA, LLC a/k/a
BREAKING MEDIA; BREAKING MEDIA, INC.
a/k/a BREAKING MEDIA; DAVID LAT; ELIE
MYSTAL; JOHN LERNER; and DAVID MINKIN;
(“ATL DEFENDANTS”);
GAWKER MEDIA, LLC a/k/a GAWKER MEDIA;
BLOGWIRE HUNGARY SZELLEMI ALKOTAST
HASZNOSITO KFT; GAWKER MEDIA GROUP,
INC. a/k/a GAWKER MEDIA; GAWKER
ENTERTAINMENT, LLC; GAWKER
TECHNOLOGY, LLC; GAWKER SALES, LLC,
NICK DENTON; IRIN CARMON; and
GABY DARBYSHIRE (“JEZEBEL
DEFENDANTS”),
Defendants.

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) Case No. 11-cv-03054
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) District Judge John J. Tharp, Jr.
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) Magistrate Judge Jeffrey T. Gilbert
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ATL DEFENDANTS’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE
THEIR REPLY IN SUPPORT OF THEIR MOTION TO DISMISS PLAINTIFF’S
FOURTH AMENDED COMPLAINT
Defendants Breaking Media, Inc. (formerly known as Breaking Media, LLC), David Lat,
Elie Mystal, John Lerner, and David Minkin (the “ATL Defendants”) respectfully request that
the Court extend by two days the deadline to file a reply in support of their motion to dismiss the
Fourth Amended Complaint of Plaintiff Meanith Huon (“Plaintiff”).
1.

On November 15, 2012, Plaintiff filed his Fourth Amended Complaint. (Dkt. No.

2.

On January 7, 2013, the ATL Defendants filed their motion to dismiss the Fourth

162.)

Amended Complaint. (Dkt. Nos. 178-181.)

3.

On January 10, 2013, this Court entered a briefing schedule; Plaintiff’s response

to the motion to dismiss would be due March 12, 2013, and the ATL Defendants’ reply would be
due April 9, 2013. (Dkt. No. 187.) On March 12, 2013, Plaintiff filed his response. (Dkt. Nos.
193-94.)
4.

Due to the press of other litigation (including two reply briefs due in a different

case on the same day as the reply brief in this matter), the ATL Defendants request two
additional days, until April 11, 2013, to file their reply brief.
5.

No party will suffer prejudice as a result of the proposed extension. This is the

ATL Defendants’ first request for an extension of the reply brief deadline.
6.

Counsel for the ATL Defendants has conferred with counsel for both Plaintiff and

the Jezebel Defendants about this request for an extension, and they do not oppose a two-day
extension.
WHEREFORE, the ATL Defendants respectfully request that this Court enter an order
extending the deadline to file a reply in support of their motion to dismiss to April 11, 2013, and
for such further relief as the Court deems appropriate.
Dated: April 9, 2013

Respectfully submitted,
BREAKING MEDIA, INC., f/k/a BREAKING
MEDIA, LLC, DAVID LAT, ELIE MYSTAL,
JOHN LERNER, and DAVID MINKIN
By:

/s/ Steven P. Mandell
One of their attorneys

Steven P. Mandell (ARDC #6183729)
Steven L. Baron (ARDC #6200868)
Elizabeth A.F. Morris (ARDC #6297239)
MANDELL MENKES LLC
One North Franklin, Suite 3600
Chicago, IL 60606
Telephone: [phone]
Facsimile: [phone]

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CERTIFICATE OF SERVICE
The undersigned, an attorney, hereby certifies that a true and correct copy of the
foregoing ATL DEFENDANTS’ UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE THEIR REPLY IN SUPPORT OF THEIR MOTION TO DISMISS
PLAINTIFF’S FOURTH AMENDED COMPLAINT has been served on April 9, 2013 via
the Court’s CM/ECF system on all counsel of record who have consented to electronic service.
Any other counsel of record will be served by electronic mail and regular mail.

/s/ Steven P. Mandell

#205148.1

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