Janson et al v. LegalZoom.com, Inc.
Filing
196
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 10/14/2011 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.
SECOND 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 a second
extension of time of one (1) day in which to file the motion for preliminary approval of
settlement in this case, until Wednesday September 28, 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.
On Friday, September 23, 2011, the parties jointly moved for an extension of four
(4) days until Tuesday, September 27, 2011. (Doc. 194.) The Court granted that motion. (Doc.
195.)
3.
The parties believe they have reached an agreement on all terms, but it is late in
the evening on Tuesday, September 27, 2011. The final terms cannot be reviewed with clients at
C072748/0306506/1051273.1
this hour or signatures obtained. Therefore, the parties jointly request a second extension of one
(1) day until Wednesday, September 28, 2011.
4.
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 one (1) day until September 28, 2011.
2
C072748/0306506/1051273.1
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
C072748/0306506/1051273.1
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