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)

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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. 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.: (816) 374-3200 Fax: (816) 374-3300 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.: (314) 259-2000 Fax: (314) 259-2020 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 2

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