Janson et al v. LegalZoom.com, Inc.
Filing
194
Joint MOTION for extension of time to File Motion for Preliminary Approval of Settlement filed by Robert M. Thompson on behalf of LegalZoom.com, Inc.. Suggestions in opposition/response due by 10/11/2011 unless otherwise directed by the court. (Thompson, Robert)
IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF MISSOURI
CENTRAL DIVISION
TODD JANSON, GERALD T. ARDREY, CHAD M.
FERRELL, and C & J REMODELING, on behalf of
themselves and on behalf of all others similarly situated,
Plaintiffs,
Case No. 2:10-cv-04018-NKL
v.
LEGALZOOM.COM, INC.,
Defendant.
JOINT MOTION FOR EXTENSION OF TIME TO FILE
MOTION FOR PRELIMINARY APPROVAL OF SETTLEMENT
Pursuant to Fed. R. Civ. P. 6(b)(1)(A), the parties jointly move the Court for an extension
of time of four (4) days in which to file the motion for preliminary approval of settlement in this
case, until Tuesday September 27, 2011.
1.
On August 12, 2011, the parties informed the Court that a settlement had been
reached in this case. In a Minute Sheet entered August 12, 2011, the Court set a date of
September 23, 2011 for filing of a motion for preliminary approval of the settlement. (Doc.
192.)
2.
The Settlement Agreement involves a number of complex issues, including
differing levels of compensation to class members depending on when their transactions took
place and prospective changes to defendant’s business practices. The parties have diligently
negotiated the terms of the Agreement and exhibits, including various forms of notice. A few
provisions require additional time and effort to finalize. The parties believe they are close to
C072748/0306506/1050844.1
final resolution of all issues and are confident they will be able to file a motion for preliminary
approval of settlement within the extended time requested.
3.
Neither party has previously requested an extension of time in which to file the
motion for preliminary approval of settlement. This joint request for an extension of time is not
made for purposes of delay and will not result in prejudice to any party.
For all the foregoing reasons, the parties respectfully request that the Court enter an
Order granting this joint motion and extending the time in which to file a motion for preliminary
approval of settlement in this case by four (4) days until September 27, 2011.
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C072748/0306506/1050844.1
Respectfully submitted,
COOK, VETTER, DOERHOFF &
LANDWEHR, PC
BRYAN CAVE LLP
By: /s/ Matthew A. Clement
Timothy Van Ronzelen
MO #44382
Matthew A. Clement
MO #43833
Kari A. Schulte
MO #57739
231 Madison
Jefferson City, Missouri 65101
By: /s/ Robert M. Thompson
Robert M. Thompson
MO #38156
James T. Wicks
MO #60409
One Kansas City Place
1200 Main Street, Suite 3500
Kansas City, Missouri 64105
David T. Butsch
MO #37539
James J. Simeri
MO #52506
BUTSCH SIMERI FIELDS LLC
231 South Bemiston Ave., Suite 260
Clayton, Missouri 63105
Michael G. Biggers
MO #25834
James R. Wyrsch
MO #24694
One Metropolitan Square -- Suite 3500
211 North Broadway
St. Louis, Missouri 63102
Edward D. Robertson, Jr.
MO #27183
Mary Doerhoff Winter
MO #38328
BARTIMUS, FRICKLETON, ROBERTSON
& GORNY
715 Swifts Highway
Jefferson City, Missouri 65109
ATTORNEYS FOR LEGALZOOM.COM,
INC.
Randall O. Barnes
RANDALL O. BARNES & ASSOCIATES
219 East Dunklin Street, Suite A
Jefferson City, Missouri 65101
Steven E. Dyer
LAW OFFICES OF STEVEN DYER
10805 Sunset Office Drive, Suite 300
St. Louis, Missouri 63127
ATTORNEYS FOR PLAINTIFFS
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C072748/0306506/1050844.1
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