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)

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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. 2 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 3 C072748/0306506/1050844.1

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