Ferris & Salter, P.C. v. Thomson Reuters Corporation

Filing 13

AMENDED NOTICE of Hearing on Motion: 4 MOTION to Dismiss/General MOTION for Extension of Time to answer or otherwise plead : Motion Hearing set for 7/11/2012 01:30 PM in Courtroom 13E (MPLS) before Judge John R. Tunheim. (Rossman, John) Modified on 6/29/2012 (akl).

UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA

Ferris & Salter, P.C.,
FILE NO. 0:12-cv-00109-JRT-SER
Plaintiff,
v.

AMENDED NOTICE OF HEARING
ON DEFENDANT’S MOTION TO
DISMISS AND TO
ENLARGE ANSWER PERIOD

Thomson Reuters Corporation,
d/b/a West Publishing Corporation,
d/b/a FindLaw,
Defendant.

TO:

Plaintiff Ferris & Salter, P.C., and its attorneys Don Ferris, Ferris & Salter, P.C.,
4158 Washtenaw Avenue, Ann Arbor, Michigan 48108, and Mark N. Jennings,
Jennings, DeWan & Anderson LLC, 6338 Main Street, North Branch, Minnesota
55056.
PLEASE TAKE NOTICE that on July 11, 2012, at 1:30 p.m. before The

Honorable John R. Tunheim, in Courtroom 13E of the U.S. Courthouse, 300 South
Fourth Street, Minneapolis, Minnesota, Defendant Thomson Reuters Corporation will
move the Court for an Order as follows:
1.

Dismissing Plaintiff’s purported “professional negligence” claim (i.e.,

Count I of the Complaint), pursuant to Fed. R. Civ. P. 12(b)(6);
2.

Extending the deadline for Defendant to answer or otherwise plead,

pursuant to Fed. R. Civ. P. 6(b)(1)(a), to a date fourteen days after the Court rules on
Defendant’s motion to dismiss Plaintiff’s purported “professional negligence” claim; and
3.

Granting such additional relief as the Court deems just and equitable.

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This motion is based upon the above-stated rules, the previously-filed
Memorandum of Law in Support of Defendant’s Motion to Dismiss and to Enlarge
Answer Period, the previously-filed Declaration of John K. Rossman (together with the
Exhibits thereto), and all of the files, records and proceedings.
Respectfully submitted,
MOSS & BARNETT
A Professional Association
Dated: June 29, 2012

By: s/John K. Rossman
Peter A. Koller (#150459)
John K. Rossman (#244831)
4800 Wells Fargo Center
90 South Seventh Street
Minneapolis, MN 55402
Telephone: [phone]
kollerp@ moss-barnett.com
[e-mail]
Attorneys for Defendant

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