Pinero v. Jackson Hewitt Tax Service Inc. et al

Filing 193

EXPARTE/CONSENT MOTION to Expedite Hearing by Jackson Hewitt Tax Service Inc., Jackson Hewitt Inc. Motion(s) referred to Daniel E. Knowles, III. (Attachments: # 1 Proposed Order)(Jackson, Veronica)

Pinero v. Jackson Hewitt Tax Service Inc. et al

Doc. 193

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,

CASE NO.: 08-3535 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. JUDGE SARAH VANCE

MAGISTRATE JUDGE DANIEL E. KNOWLES

EX PARTE MOTION FOR EXPEDITED HEARING OF MOTION TO COMPEL DEPOSITION OF PLAINTIFF VICKI L. PINERO, OR ALTERNATIVELY, TO STAY DISCOVERY NOW INTO COURT, through undersigned counsel, comes Defendants Jackson Hewitt Tax Service Inc. and Jackson Hewitt Inc. ("Jackson Hewitt"), who moves the Court for expedited hearing if its Motion to Compel the Deposition of Vicki L. Pinero, or Alternatively, To Stay Discovery ("Motion to Compel"). This motion is relevant to other pending motions which are scheduled for oral argument on September 23, 2009 at 11:00 a.m. See Jackson Hewitt's Motion for Protective Order/Confidentiality Order, Docket Entry No. 179; Plaintiff's Motion to Compel, Docket Entry No. 189. Therefore, in the interest of judicial efficiency, Jackson Hewitt seeks to have its motion heard on this same date. Pursuant to Local Rule 7.2, Jackson Hewitt's Motion to Compel is currently scheduled for hearing on September 30, 2009.

Dockets.Justia.com

WHEREFORE, Jackson Hewitt requests that it be granted an expedited hearing of its Motion to Compel on September 23, 2009, at 11:00 a.m. Date: September 9, 2009 By Attorneys: __/s/ Veronica D. Jackson_______ Donna L. Wilson (Admitted pro hac vice) Andrew S. Wein (Admitted pro hac vice) Veronica D. Jackson (Admitted pro hac vice) KELLEY DRYE & WARREN LLP 3050 K Street, NW, Suite 400 Washington, DC 20007 Telephone: [phone] 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: [phone] Attorneys for Jackson Hewitt Tax Service Inc. and Jackson Hewitt Inc.

CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 9th day of September, 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 to counsel of record for Plaintiff and Crescent City Tax Service, Inc. __/s/_Veronica D. Jackson______

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