Brady et al v. National Football League et al

Filing 181

Second MOTION for Extension of Time of Briefing Schedule (Amended) by Arizona Cardinals Football Club, Inc., Atlanta Falcons Football Club, LLC, Baltimore Ravens Limited Partnership, Tom Brady, Drew Brees, Buccaneers Limited Partnership, Buffalo Bills, Inc., Chargers Football Company, LLC, Chicago Bears Football Club, Inc., The, Cinncinnati Bengals, Inc., Cleveland Browns Football Company LLC, Dallas Cowboys Football Club, Ltd., Detroit Lions, Inc., The, Football Northwest LLC, Green Bay Packers, Inc., Houston NFL Holdings, LP, Indianapolis Colts, Inc., Vincent Jackson, Jacksonville Jaguars, Ltd., Kansas City Chiefs Football Club, Inc., Ben Leber, Logan Mankins, Peyton Manning, Miami Dolphins, Ltd., Von Miller, Minnesota Vikings Football, LLC, National Football League, New England Patriots LP, New Orleans Louisiana Saints, LLC, New York Football Giants, Inc., New York Jets LLC, Oakland Raiders LP, The, PDB Sports, Ltd., Panthers Football, LLC, Philadelphia Eagles, LLC, Pittsburgh Steelers Sports, Inc., Pro-Football, Inc., Rams Football Co, LLC, The, Brian Robison, San Diego Chargers Football Co., San Francisco Forty Niners Ltd., St. Louis Rams Partnership, The, Tennessee Football, Inc., Osi Umenyiora, Mike Vrabel, Washington Football Inc.. (Connolly, Daniel)

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UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA _____________________________________________________________________ TOM BRADY, et al., Civ. No. 11-CV-00639-SRN-JJG Plaintiffs, v. NATIONAL FOOTBALL LEAGUE et al., SECOND AMENDED JOINT MOTION FOR EXTENSION OF BRIEFING SCHEDULE Defendants. _____________________________________________________________________ The Brady Plaintiffs and the NFL Defendants hereby jointly move for a further one-week extension of the due date from July 25, 2011 to August 1, 2011 for the NFL Defendants’ opening memorandum in support of its dispositive motion to be heard at the August 29, 2011 hearing. The parties do not at this time request any change to the hearing date. The parties make this joint request to allow them to focus on the continuing mediation ordered by the Court (Dkt. No. 56). With the Court’s guidance, the parties previously scheduled a hearing date of August 29, 2011 at 1:30 p.m. for the NFL Defendants’ motions to dismiss the governing complaints and for possible dispositive motions by the Brady Plaintiffs. At the Court’s direction (Dkt. No. 56), the parties have also been meeting regularly since April 11, 2011, in an effort to resolve their disputes. Both the Brady Plaintiffs and the NFL Defendants agree that postponing the deadline for filing the NFL Defendants’ opening memoranda by an additional week will aid their continuing court-ordered discussions. The parties therefore respectfully request the Court to issue an order allowing the NFL Defendants to file their opening memorandum on August 1, 2011. Respectfully submitted, Respectfully submitted, Dated: July 22, 2011 Dated: July 22, 2011 By: s/Daniel J. Connolly Daniel J. Connolly, #197427 Aaron D. Van Oort, #315539 FAEGRE & BENSON LLP 2200 Wells Fargo Center 90 South Seventh Street Minneapolis, MN 55402-3901 Telephone (612) 766-7806 Facsimile (612) 766-1600 By: s/ Barbara P. Berens Barbara P. Berens #209788 Justi Rae Miller #387330 BERENS & MILLER, P.A. 3720 IDS Center 80 South Eighth Street Minneapolis, MN 55402 (612) 349-6171 Attorneys for Brady Plaintiffs Attorneys for Defendants 2

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