Janson et al v. LegalZoom.com, Inc.

Filing 104

Joint MOTION for extension of time to respond to Summary Judgment Motions filed by Matthew A. Clement on behalf of All Plaintiffs. Suggestions in opposition/response due by 5/13/2011 unless otherwise directed by the court. (Clement, Matthew)

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF MISSOURI
CENTRAL DIVISION
TODD JANSON, et al.,
Plaintiffs,
v.
LEGALZOOM.COM, INC.,
Defendant.

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Case No. 10-04018-CV-C-NKL

JOINT MOTION FOR EXTENSION OF TIME
TO RESPOND TO MOTIONS FOR SUMMARY JUDGMENT AND
TO ALLOW PLAINTIFFS TO EXCEED PAGE LIMITS

Come now the parties and jointly move for an Order of this Court granting each an
extension of time through and including May 12, 2011 by which to file a response to each other’s
Motion for Summary Judgment. In addition, Plaintiffs move, without objection from Defendant,
for an Order granting them leave to exceed the page limits by ten (10) pages for their Response
to Defendant’s Motion for Summary Judgment. In support of this Motion, the parties state as
follows:
1.

On April 8, 2011, Plaintiffs filed a Motion for Partial Summary Judgment and

Defendant filed a Motion for Summary Judgment. The docket entry for each of these filings
state the response to each Motion is due to be filed on May 2, 2011.
2.

On April 14, 2011, both parties filed Motions asking the Court to allow the

Summary Judgment Motions be maintained under seal. Those Motions were granted and
Defendant re-filed its Motion for Summary Judgment on April 15, 2011. The docket entry for

Defendant’s re-filed Motion indicates that the response to this Motion is due to be filed on May
9, 2011.
3.

Due to travel schedules and other previously scheduled matters, the parties are

each requesting a short extension of time through and including May 12, 2011, to file their
respective responses to each other’s Motions for Summary Judgment.
4.

This is the first extension requested by each party, and the parties do not believe it

will impact the trial date.
5.

Finally, Defendant was given leave to exceed the page limits for the Suggestions

in Support of its Motion for Summary Judgment such they did not exceed twenty-five (25)
pages, exclusive of facts. Accordingly, Plaintiffs request that they be allowed to exceed the page
limits by ten (10) pages as well for their Response, such that they are allowed to file Suggestions
in Opposition to Defendant’s Motion for Summary Judgment not to exceed twenty-five (25)
pages, exclusive of facts. Defendant does not object to this request.
WHEREFORE, the parties respectfully request that the Court grant both parties an
extension of time to respond to the other party’s Motion for Summary through and including
May 12, 2011, and that Plaintiffs be allowed to file Suggestions in Opposition to Defendant’s
Motion for Summary Judgment that do not exceed twenty-five (25) pages exclusive of facts.
Respectfully submitted,

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COOK, VETTER, DOERHOFF &
LANDWEHR, PC

BRYAN CAVE LLP

By: /s/ Matthew A. Clement
Timothy Van Ronzelen
Matthew A. Clement
Kari A. Schulte
231 Madison
Jefferson City, MO 65101
Tel: [phone]
Fax: [phone]

By: /s/ James T. Wicks
Robert M. Thompson MO #38156
James T. Wicks
MO #60409
One Kansas City Place
1200 Main Street, Suite 3500
Kansas City, MO 64105
Tel.: [phone]
Fax: [phone]

David T. Butsch
James J. Simeri
Mathew R. Fields
BUTSCH SIMERI FIELDS LLC
231 South Bemiston Ave., Suite 260
Clayton, MO 63105

Michael G. Biggers MO #24694
James R. Wyrsch
MO #53197
One Metropolitan Square – Suite 3600
211 North Broadway
St. Louis, MO 63102
Tel.: [phone]
Fax: [phone]

Edward D. Robertson, Jr.
Mary Doerhoff Winter
BARTIMUS, FRICKLETON, ROBERTSON
& GORNY
715 Swifts Highway
Jefferson City, MO 65109

ATTORNEYS FOR DEFENDANT
LEGALZOOM.COM, INC.

Randall O. Barnes
RANDALL O. BARNES & ASSOCIATES
219 East Dunklin Street, Suite A.
Jefferson City, MO 65101
Steven E. Dyer
10805 Sunset Office Drive, Suite 300
St. Louis, MO 63127
ATTORNEYS FOR PLAINTIFFS

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