Pinero v. Jackson Hewitt Tax Service Inc. et al

Filing 124

Request/Statement of Oral Argument by Jackson Hewitt Tax Service Inc., Jackson Hewitt Inc regarding 123 MOTION to Dismiss Case (Wein, Andrew)

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Pinero v. Jackson Hewitt Tax Service Inc. et al Doc. 124 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA VICKI L. PINERO, individually and on behalf of all others similarly situated, Plaintiff, SECTION R v. JACKSON HEWITT TAX SERVICE INC.; JACKSON HEWITT INC.; and, CRESCENT CITY TAX SERVICE, INC. d/b/a JACKSON HEWITT TAX SERVICE, Defendants. REQUEST FOR ORAL ARGUMENT NOW INTO COURT, through undersigned counsel and pursuant to L.R. 78.1, comes Defendants Jackson Hewitt Tax Service Inc. and Jackson Hewitt Inc. (collectively "Jackson Hewitt"). Jackson Hewitt has contemporaneously filed a Rule 12(b)(6) Motion to Dismiss Plaintiff's Third Amended Complaint. The Court should hear oral argument on Jackson Hewitt's motion. The lawsuit and motion involve complex legal matters. Oral argument would provide an opportunity for the parties to clearly state their position and assist the Court in addressing the related legal issues. WHEREFORE, Jackson Hewitt requests that the Court grant its request for oral argument on the contemporaneously filed Rule 12(b)(6) Motion to Dismiss Plaintiff's Third Amended Complaint. JUDGE SARAH VANCE MAGISTRATE JUDGE DANIEL E. KNOWLES CASE NO.: 08-3535 Date: May 4, 2009 Dockets.Justia.com Respectfully Submitted, By Attorneys: __/s/Andrew S. Wein___________ Donna L. Wilson (Admitted pro hac vice) Andrew S. Wein (Admitted pro hac vice) Veronica D. Gray (Admitted pro hac vice) KELLEY DRYE & WARREN LLP 3050 K Street, NW, Suite 400 Washington, DC 20007 Telephone: (202) 342-8400 AND KEAN, MILLER, HAWTHORNE, D'ARMOND, McCOWAN & JARMAN, L.L.P. Glenn M. Farnet (#20185) Gina D. Banks (#27440) One American Place, 18th Floor Post Office Box 3513 (70821) Baton Rouge, Louisiana 70825 Telephone: (225) 387-0999 Attorneys for Jackson Hewitt Tax Service Inc. and Jackson Hewitt Inc. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 4th day of May, 2009, a copy of the foregoing was electronically filed with the Clerk of Court using the CM/ECF system. Notice of this filing will be sent by operation of the Court's electronic filing system and U.S. Mail to counsel of record for Plaintiffs. A copy of this filing will also be sent via electronic mail and U.S. mail to counsel for Crescent City Tax Service, Inc. __/s/Andrew S. Wein___________ -2-

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