Pinero v. Jackson Hewitt Tax Service Inc. et al

Filing 106

EXPARTE/CONSENT MOTION for Leave to File Reply by Vicki L. Pinero. Motion(s) referred to Daniel E. Knowles, III. (Attachments: # 1 Proposed Order, # 2 Proposed Pleading Plaintiff's Reply to Memorandum in Opposition to Ex Parte Motion to Amend Document No. 77)(Shartle, Bryan)

Pinero v. Jackson Hewitt Tax Service Inc. et al

Doc. 106

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA VICKI L. PINERO, individually and on ) ) behalf of all others similarly situated, ) ) Plaintiffs, ) ) v. ) JACKSON HEWITT TAX SERVICE ) INC.; JACKSON HEWITT INC.; and, ) CRESCENT CITY TAX SERVICE, INC. ) d/b/a JACKSON HEWITT TAX ) ) SERVICE, ) ) Defendants. Civil Action No. 08-03535 Sec. R JUDGE SARAH S. VANCE Mag. 3 MAGISTRATE KNOWLES, III JUDGE DANIEL E.

PLAINTIFF VICKI L. PINERO'S EX PARTE MOTION FOR LEAVE TO FILE REPLY TO MEMORANDUM IN OPPOSITION TO EX PARTE MOTION TO AMEND DOCUMENT NUMBER 77 NOW INTO COURT, through undersigned counsel, comes plaintiff, Vicki L. Pinero,

and pursuant to L.R. 7.4, moves this Court for leave to file a memorandum in reply to the arguments raised made by defendants, Jackson Hewitt Tax Service Inc. and Jackson Hewitt Inc. (jointly referred to as "Jackson Hewitt"), in its opposition memorandum [Docket No. 104] to plaintiff's Ex Parte Motion to Amend Document No. 77 [Docket No. 103]. The proposed memorandum is attached hereto. 1

Dockets.Justia.com

Plaintiff's proposed memorandum addresses Jackson Hewitt's allegations of plaintiff's and undersigned counsel's alleged improprieties, provides needed background regarding the filing of the disputed motion, and will otherwise aid this Court's understanding and disposition of the matters presently in dispute.
WHEREFORE, plaintiff prays for an order granting plaintiff leave to file the attached

reply memorandum in response to the arguments raised by Jackson Hewitt in its opposition to plaintiff's Ex Parte Motion to Amend Document No. 77. Respectfully Submitted, /s/ Bryan C. Shartle David Israel (LSBA No. 7174) (T.A.) Bryan C. Shartle (LSBA No. 27640) Justin H. Homes (LSBA No. 24460)
SESSIONS, FISHMAN, NATHAN & ISRAEL, L.L.P.

CERTIFICATE OF SERVICE I hereby certify that a copy of the above and foregoing has been forwarded to all counsel of record by ECF; __ by email; __ by hand; __ by fax; __ by FedEx; __ by placing a copy of same in the U.S. Mail, postage prepaid this 8th day of April 2009. /s/ Bryan C. Shartle Bryan C. Shartle

3850 N. Causeway Blvd. Lakeway II, Suite 200 Metairie, Louisiana 70002 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff, Vicki L. Pinero

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