Virgin Records America, Inc v. Thomas

Filing 358

MOTION for Extension of Time to File Response/Reply as to 351 Order on Motion for Extension of Time to File Response/Reply (Reply to have been filed 8/21/09) by Arista Records LLC, Capitol Records, Inc, Interscope Records, Sony BMG Music Entertainment, UMG Recordings, Inc, Warner Bros Records Inc. (Mohraz, Andrew)

Download PDF
Virgin Records America, Inc v. Thomas Doc. 358 Case 0:06-cv-01497-MJD-RLE Document 358 Filed 08/20/09 Page 1 of 3 IN THE UNITED STATES OF DISTRICT COURT FOR THE DISTRICT OF MINNESOTA CAPITOL RECORDS, INC., et al., Plaintiffs, vs. JAMMIE THOMAS-RASSET, Defendant. Plaintiffs respectfully submit this Unopposed Motion for Extension to File Reply Briefs and state as follows: 1. 338.) 2. The parties each filed post-trial motions on July 6, 2009. Plaintiffs filed a Motion On June 19, 2009, the Court entered Judgment against Defendant. (Doc. No. Case No.: 06cv1497-MJD/RLE UNOPPOSED MOTION FOR EXTENSION TO FILE REPLY BRIEFS to Amend Judgment (Doc. No. 342) and Defendant filed a Motion for a New Trial, Remittitur, and to Alter or Amend the Judgment (Doc. No. 344). 3. On July 8, 2009, the Court issued a Briefing Notice (Doc. No. 345), instructing that opposition briefs be filed by July 22, 2009 and replies by July 29, 2009. Based on Plaintiffs' Unopposed Motion (Doc. No. 346), the Court entered an Order (Doc. No. 348) amending the briefing schedule to allow the parties to file opposition briefs by August 12, 2009 and replies by August 19, 2009. The Court again extended these deadlines by two days upon Plaintiffs' Unopposed Motion (Doc. No. 349) and entered an Order (Doc. No. 351) resetting the deadlines to file opposition briefs by August 14, 2009 and replies by August 21, 2009. #1425474 v1 den Dockets.Justia.com Case 0:06-cv-01497-MJD-RLE Document 358 Filed 08/20/09 Page 2 of 3 4. On August 21, 2009, Plaintiffs filed their opposition brief (Doc. No. 353), Defendant filed her opposition brief (Doc. No. 355)1, and the United States of America filed an memorandum of law (Doc. No. 352) regarding Defendant's Motion for a New Trial (Doc. No. 344). 5. Plaintiffs now respectfully request a seven-day extension of the deadline to file their reply brief to accommodate certain Plaintiffs' representatives who have been out of the office this week. The brief extension will allow Plaintiffs to finalize their opposition brief and file it by Friday, August 28, 2009. 6. Undersigned counsel for Plaintiffs has conferred with counsel for Defendant regarding this motion. Defendant has no objection to the motion provided that the deadline for replies be extended for all parties. 7. Accordingly, Plaintiffs respectfully submit that good cause exists for extending the deadline to file reply briefs by seven days to August 28, 2009. No party would be prejudiced were this Court to grant the requested extension. WHEREFORE, Plaintiffs respectfully request that the Court extend the deadline to file reply briefs on post-trial motions by seven days, and enter an order resetting this deadline for all parties to August 28, 2009. A form of order has been sent to chambers for the Court's convenience. 1 Defendant subsequently filed a corrected opposition brief on August 15, 2009 (Doc. No. 357). 2 #1425474 v1 den Case 0:06-cv-01497-MJD-RLE Document 358 Filed 08/20/09 Page 3 of 3 Respectfully submitted this 20th day of August 2009. /s/ Andrew B. Mohraz Timothy M. Reynolds (pro hac vice) David A. Tonini (pro hac vice) Andrew B. Mohraz (pro hac vice) HOLME ROBERTS & OWEN LLP 1700 Lincoln, Suite 4100 Denver, Colorado 80203 Telephone: (303) 861-7000 Facsimile: (303) 866-0200 Matthew J. Oppenheim (pro hac vice) THE OPPENHEIM GROUP, LLP 7304 River Falls Drive Potomac, Maryland 20854 Telephone: (301) 299-4986 Facsimile: (866) 766-1678 Felicia J. Boyd (No. 186168) Leita Walker (No. 387095) FAEGRE & BENSON LLP 2200 Wells Fargo Center 90 South Seventh Street Minneapolis, Minnesota 55402-3901 Telephone: (612) 766-7000 Facsimile: (612) 766-1600 ATTORNEYS FOR PLAINTIFFS 3 #1425474 v1 den

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?