Virgin Records America, Inc v. Thomas

Filing 30

MEMORANDUM in Support re 29 MOTION to Amend/Correct 17 Scheduling Order, Stipulated Motion to Amend Pretrial Scheduling Order filed by Jammie Thomas. (Toder, Brian)

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Virgin Records America, Inc v. Thomas Doc. 30 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MINNESOTA VIRGIN RECORDS AMERICA, INC., a California corporation; CAPITOL RECORDS INC., a Delaware corporation; SONY BMG MUSIC ENTERTAINMENT, a Delaware general partnership; ARISTA RECORDS LLC, a Delaware limited liability company; INTERSCOPE RECORDS, a California general partnership; WARNER BROS. RECORDS INC., a Delaware corporation; and UMG RECORDINGS, INC., a Delaware corporation, Plaintiffs, v. Jammie Thomas, Defendant. Case No. 06-cv-1497 (MJD/RLE) MEMORANDUM IN SUPPORT OF STIPULATED MOTION TO AMEND PRETRIAL SCHEDULING ORDER Defendant's undersigned counsel and plaintiffs' counsel have filed a Stipulated Motion to Amend the Pretrial Scheduling Order. This motion is brought at the behest of counsel for defendant who seeks a later date for which this case is to be ready for trial. The Order of March 6, 2007, of the Honorable Raymond L. Erickson, Chief U.S. Magistrate Judge, requires this case to be ready for trial on August 1, 2007 [Docket No. 17]. The Order emphasizes that this date is not a trial setting date. Certain developments in the course of this litigation compel defendant's counsel to withdraw. Extending the date for which this case is to be ready for trial will ensure that 1 defendant will have sufficient time to engage other counsel who will have a sufficient time to properly prepare. Defendant's counsel respectfully requests that the court amend the pretrial scheduling order to provide for the case being ready for trial in the late Fall of 2007. After the Court decides the instant motion, defendant's undersigned counsel will bring a motion to withdraw as provided in the Local Rules. Dated: June 8, 2007 Respectfully submitted, CHESTNUT & CAMBRONNE, P.A. By /s/ Brian N. Toder Brian N. Toder (No. 17869X) 3700 Campbell Mithun Tower 222 South Ninth Street Minneapolis, MN 55402 (612) 339-7300 Fax (612)336-2940 ATTORNEYS FOR DEFENDANT 2

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