Janson et al v. LegalZoom.com, Inc.

Filing 48

Joint MOTION for extension of time of the Briefing Schedule on Plaintiffs' Motion for Class Certification filed by Robert M. Thompson on behalf of All Parties. Suggestions in opposition/response due by 10/8/2010 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 THE BRIEFING
SCHEDULE ON PLAINTIFFS’ MOTION FOR CLASS CERTIFICATION
Pursuant to Fed. R. Civ. P. 6(b)(1)(A), the parties jointly move the Court for an extension
of time in which to submit briefing related to Plaintiffs’ Motion for Class Certification until
October 8, 2010, eight (8) days after completion of Court ordered mediation, with any reply to be
filed on or before October 18, 2010.
1.

The Scheduling Order in this case set a date of August 27, 2010 for Plaintiffs to

move for class certification.

Defendant’s brief in opposition is to be filed on or before

September 24, 2010, with any reply brief to be filed on or before October 12, 2010. (See Doc.
22.)
2.

Plaintiffs filed their Motion for Class Certification and Suggestions in Support on

August 27, 2010. (Docs. 45 and 46.)
3.

On September 2, 2010, the Court assigned this case to the University of Missouri

Law School Mediation Clinic for mediation. (Doc. 47.)

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4.

The parties have scheduled mediation with the University of Missouri Law

School Mediation Clinic on September 30, 2010. Because the outcome of mediation may affect
the issues to be addressed in the parties’ briefing on class certification, briefing class certification
while mediation is ongoing would be an inefficient use of the parties’ and the Court’s resources.
5.

Accordingly, the parties seek a short extension of the briefing schedule on class

certification to allow the parties to complete the mediation prior to completing briefing on
Plaintiffs’ Motion for Class Certification. The parties request that the Court extend the time for
filing of Defendants’ response until October 8, 2010, which is eight (8) days after the mediation,
with Plaintiffs’ reply due October 18, 2010, which is ten (10) days later.
6.

This request for an extension of time is not made for the purpose of delay. The

requested extension will not result in prejudice to any party and will only extend the prior
briefing period by six (6) days.
7.

The parties have made no previous motions to extend the briefing schedule on

Plaintiffs’ Motion for Class Certification.
For all the foregoing reasons, the parties respectfully request that the Court enter an
Order granting this motion and extending the deadlines to the dates set out above.

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Respectfully submitted,
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, Missouri 65101

By: /s/ Robert M. Thompson
Robert M. Thompson
James T. Wicks
One Kansas City Place
1200 Main Street, Suite 3500
Kansas City, Missouri 64105

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

Michael G. Biggers
James R. Wyrsch
One Metropolitan Square -- Suite 3500
211 North Broadway
St. Louis, Missouri 63102

Edward D. Robertson, Jr.
Mary Doerhoff Winter
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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