Janson et al v. LegalZoom.com, Inc.

Filing 83

Consent MOTION for leave to file excess pages for suggestions in Support of Motion for Summary Judgment filed by Robert M. Thompson on behalf of LegalZoom.com, Inc.. Suggestions in opposition/response due by 4/21/2011 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.

DEFENDANT’S UNOPPOSED MOTION FOR LEAVE
TO FILE SUGGESTIONS IN SUPPORT OF MOTION
FOR SUMMARY JUDGMENT IN EXCESS OF 15 PAGES
Defendant LegalZoom.com, Inc. (“LegalZoom”) respectfully requests leave to file its
Suggestions in Support of its Motion for Summary Judgment in excess of fifteen (15) pages. In
support of this request, LegalZoom states as follows:
Under the Court’s March 11, 2010 Scheduling Order, LegalZoom is to file its Motion for
Summary Judgment and supporting papers on April 8, 2011. Plaintiffs’ Petition alleges that,
under Missouri law, LegalZoom is prohibited from conducting business in Missouri. LegalZoom
needs additional pages to adequately address the number of significant issues at stake in its
motion for summary judgment. In accordance with Local Rule 7.1(f), LegalZoom requests the
Court’s permission to include up to ten (10) additional pages in its Suggestions. LegalZoom has
consulted with counsel for Plaintiffs, who have consented to this request.
WHEREFORE, LegalZoom respectfully requests the Court’s permission to include up to
ten (10) additional pages in its Suggestions in Support of its Motion for Summary Judgment in
accordance with Local Rule 7.1(f).

Respectfully submitted,
BRYAN CAVE LLP
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, MO 64105
Tel.: [phone]
Fax: [phone]
John Michael Clear
MO #25834
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]
Attorneys for LegalZoom.com, Inc.

CERTIFICATE OF SERVICE
I hereby certify that on April 4, 2011, I electronically filed the above and foregoing with
the clerk of court using the CM/ECF system, which will send notice of electronic filing to all
counsel of record.

s/ Robert M. Thompson
Attorney for Defendant

1033426.1

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