STELOR PRODUCTIONS, INC. v. OOGLES N GOOGLES et al

Filing 82

Unopposed MOTION for Extension of Time to March 31, 2008 To File Expert Disclosure, filed by Plaintiff STELOR PRODUCTIONS, LLC.. (Attachments: # 1 Text of Proposed Order)(Hoover, John)

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STELOR PRODUCTIONS, INC. v. OOGLES N GOOGLES et al Doc. 82 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION STELOR PRODUCTIONS, INC. Plaintiff, vs. OOGLES N GOOGLES, an Indiana corporation; KEVIN MENDELL; DANYA MENDELL; MICHELLE COTE; ROB LENDERMAN; STACEY LENDERMAN; BRENDA MURTY; MARGIE THOMAS; ROB SLYTER; ELIZABETH SLYTER; CORINNA SPARKS; CHRISTINE WATERBURRY; LEIGH SUNDLING; and TINA CARTAYA, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 1:05-cv-0354-DFH-TAB PLAINTIFF STELOR PRODUCTIONS, INC.'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE EXPERT DISCLOSURE Plaintiff STELOR PRODUCTIONS, INC. ("STELOR"), by and through its undersigned counsel, hereby files its Unopposed Motion for Extension of Time to file the Expert Disclosure, and states as follows: 1. STELOR's expert witness disclosure is currently due on or before February 29, 2008. 2. Counsel for STELOR is in the process of getting the expert disclosures filed, however, due to issues surrounding the substitution of counsel, the Plaintiff is in need of additional time to file the expert disclosure. 3. Based upon the foregoing, STELOR respectfully requests an extension of time up to and including March 31, 2008, to file the expert disclosure. 4. Counsel for STELOR has conferred with counsel for OOGLES N GOOGLES, and counsel for OOGLES N GOOGLES has no objection to the granting of this Motion. 5. The instant motion is filed in good faith and not for the purposes of delay. Dockets.Justia.com WHEREFORE, Plaintiff STELOR PRODUCTIONS, INC. respectfully requests that this Court enter an Order granting an extension of time, up to and including March 31, 2008 to file its Expert Disclosure, together with such other and further relief as this Court deems just and proper. Respectfully submitted, s/John David Hoover _ John David Hoover, Attorney No. 7945-49 HOOVER HULL LLP Attorneys at Law 111 Monument Circle, Ste. 4400 P.O. Box 44989 Indianapolis, IN 46244-0989 Phone: (317) 822-4400 Fax: (317) 822-0234 E-mail: jdhoover@hooverhull.com Of counsel: Kevin C. Kaplan (admitted pro hac vice) Burlington, Weil, Schwiep, Kaplan & Blonsky, P.A. 2699 S. Bayshore Drive PH Miami, Florida 33133 Tel: (305) 858-2900 Fax: (305) 858-5261 Email: kkaplan@bwskb.com Attorneys for Plaintiff, Stelor Productions, Inc. CERTIFICATE OF SERVICE I hereby certify that on February 29, 2008, a copy of the foregoing Plaintiff Stelor Productions, Inc.'s Unopposed Motion for Extension of Time to File Expert Disclosure was filed electronically. Notice of this filing will be sent to the following party by operation of the Court's electronic filing system. Parties may access this filing through the Court's system. Stephen L. Vaughan Steve@IPLawIndiana.com s/John David Hoover John David Hoover HOOVER HULL LLP Attorneys at Law 111 Monument Circle, Ste. 4400 P.O. Box 44989 Indianapolis, IN 46244-0989 Phone: (317) 822-4400 Fax: (317) 822-0234 E-mail: jdhoover@hooverhull.com

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