Huon v. Breaking Media et al

Filing 52

MOTION by Plaintiff Meanith Huon for extension of time to file response/reply as to motion for extension of time to file response/reply, motion for relief,,,,,,,, 51 , memorandum in support of motion 49 , terminate hearings, motion hearing, set motion and R&R deadlines/hearings,,, 46 , MOTION by Plaintiff Meanith Huon for leave to file excess pages (AMENDED MOTION) (Huon, Meanith)

IIN THE UNITED STATES DISTRICT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

MEANITH HUON,
Plaintiff,
v.

ABOVETHELAW.COM,

et. al.
Defendants

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) CIVIL ACTION NO.: 1: 11-cv-3054
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AMENDED MOTION TO MODIFY BRIEFING SCHEDULE
AND FOR AN EXTENSION OF TIME
AND TO FILE A RESPONSE BRIEF IN EXCESS OF 15 PAGES
Plaintiff, Meanith Huon, states as follows:
1.

Defendants, Breaking Media, LLC, Breaking Media, Breakingmedia.com, David
Lat, John Lerner, Abovethelaw.com, Elie Mystal, (“The Above the Law”
Defendants”) filed a Motion to Dismiss and a 22-page Memorandum of Law with
Exhibits in Excess of 170 pages.

2.

Defendants’ Responsive Pleading was originally due on or about August 4, 2011,
after Defendants were given 60 days to respond to the Complaint.

3.

Defendants moved, without opposition from Plaintiff, for an extension of time to
August 22, 2011, and then to September 21, 2011, to respond.

4.

Defendants have had more than 3 months to prepare their Motion to Dismiss and
Memorandum of Law, which contains a table of contents.

5.

Plaintiff anticipates that he will need additional time to respond to The
AboveTheLaw.Com Defendants’ lengthy Memorandum and that he will need more

than 15 pages to respond.
6.

The responsive pleadings of the Defendants, Defendants Irin Carmon, Gabby
Darbyshire, Nick Denton, Gawker Media, Jezebel.com (the “Jezebel.com
Defendants”) are not yet due.

7.

The AboveTheLaw Defendants will not be prejudiced by granting Plaintiff more
time to respond.

8.

Plaintiff, Meanith Huon, is representing himself pro se. Mr. Huon has other
professional obligations in state and federal court. He is assistant general counsel to
Aidan Monahan and Monahan Properties, LLC; he is assistant general counsel to
Flava Works, Inc.. Mr. Huon maintains his own law practice. Mr. Huon started a full
time attorney position with a law firm on September 26, 2011.

9.

Mr. Huon also filed a motion for the Defendants to produce the complete trial
transcript attached as Exhibit B to their Memorandum. The Court referred this matter
to Magistrate Judge Gilbert for ruling. The parties need time for Judge Gilbert to rule
on this matter before Plaintiff files his Response brief.

10.

The next Court status date is December 22, 2011.
WHEREFORE, Plaintiff, Meanith Huon, requests that this Honorable Court:

1.

Modify the briefing schedule to give Plaintiff 35 days, or until October 31, 2011,
to file a response brief and to give The AboveTheLaw Defendants until November 7,
2011 to reply.

2.

Grant Plaintiff leave to file a Response brief in excess of 15 pages.

Respectfully Submitted,
By: /s/ Meanith Huon /s/
Meanith Huon
Meanith Huon
ARDC No.: 6230996
PO Box 441
Chicago, IL 60690
312-405-2789
[e-mail]

IN THE UNITED STATES DISTRICT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

MEANITH HUON,
Plaintiff,
v.

FORMER MADISON COUNTY STATE'S
ATTORNEY WILLIAM MUDGE, et. al.

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CIVIL ACTION NO. 11-3050
JURY TRIAL DEMANDED

CERTIFICATE OF SERVICE
Under penalties of law, I attest the following documents or items have been or are being
electronically served on all counsel of record for all parties on September 26, 2011:

AMENDED MOTION TO MODIFY BRIEFING SCHEDULE
AND FOR AN EXTENSION OF TIME
AND TO FILE A RESPONSE BRIEF IN EXCESS OF 15 PAGES

Respectfully submitted,
/s/ Meanith Huon
Meanith Huon
PO Box 441
Chicago, Illinois 60690
Phone: [phone]
E-mail: [e-mail]
IL ARDC. No.: 6230996