Huon v. Breaking Media et al

Filing 85

MEMORANDUM by Gabby Darbyshire, Nick Denton, Gawker Media, Jezebel.com in Opposition to motion for leave to file excess pages,, motion for extension of time to file response/reply,, motion for relief,,, 82 (Feige, David)

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

MEANITH HUON,
Plaintiff,
-againstGAWKER MEDIA A/K/A GAWKER.COM,
JEZEBEL.COM, NICK DENTON, IRIN
CARMON & GABY DARBYSHIRE
Defendants

)
)
)
)
)
)
)
)
)
)
)
)

CIVIL ACTION NO.:
1:11-CV-3054 (MEA JTG)

GAWKER DEFENDANT’S OPPOSITION TO PLAINTIFF’S REQUEST FOR
ADDITIONAL TIME AND PAGES

1. On October 12, 2011, after a conference with the Court, the Court gave Mr. Huon
until November 30, 2011 to respond to both the Above the Law Defendants’ and
the Gawker Defendants’ Motions to Dismiss. Defense counsel relied on this
schedule.

2. After the close of business on November 30, 2011, Plaintiff filed a motion for
additional pages and more time to respond to the Gawker Defendant’s motion to
dismiss.

3. Plaintiff offers no specific reason, explanation, or good cause to support his latebreaking desire to have additional time to respond to the instant defendants.

Rather, all of the substantive paragraphs of his motion (Paragraphs 3-10)
complain about co-defendant abovethelaw.com’s actions.

4. As Plaintiff well knows, his request requires Defendants to respond during the
week of Christmas and the week between Christmas and New Year’s.

5. Plaintiff is thus far on his second amended complaint and has filed over half a
dozen motions. This is the second time he has moved for an extension of time.

6. The Gawker Defendants merely seek a predictable schedule and an expeditious
resolution to Plaintiff’s $100,000,000.00 (one hundred million dollar) suit, and as
such must oppose Plaintiff’s eleventh hour request.

WHEREFORE the defendants pray that the court deny plaintiff’s motion for more time
and additional pages and grant other such relief as the court should deem appropriate.
Dated: New York, New York
December 1, 2011

Respectfully Submitted,
GAWKER MEDIA A/K/A
GAWKER.COM, JEZEBEL.COM,
NICK DENTON, IRIN CARMON
& GABY DARBYSHIRE,
By: ____/S/ David Feige_________
One of their attorneys

David Feige
Oren S. Giskan
GISKAN SOLOTAROFF ANDERSON
& STEWART LLP
11 Broadway, Suite 2150

New York, NY 10004
T: 212.847-8315
F: 646.520.3235
[e-mail]
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 ___________________

Dated: New York, New York
December 1, 2011

Respectfully Submitted,

By: ____/S/ David Feige_________
David Feige

David Feige
Oren S. Giskan
GISKAN SOLOTAROFF ANDERSON
& STEWART LLP
11 Broadway, Suite 2150
New York, NY 10004
T: 212.847-8315
F: 646.520.3235
[e-mail]