IHOP IP, LLC et al v. International House of Prayer et al

Filing 40

Consent MOTION for extension of time to Amend the Return of Service and Strike Certain Affirmative Defenses filed by Elizabeth A. Tassi on behalf of All Plaintiffs. Suggestions in opposition/response due by 1/26/2012 unless otherwise directed by the court. (Tassi, Elizabeth)

IN THE UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF MISSOURI
IHOP IP, LLC et al.,

Plaintiffs,
vs.
INTERNATIONAL HOUSE OF PRAYER
et al.,

Defendants.

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Case No.: 11-00548-CV-W-NKL

UNOPPOSED MOTION FOR EXTENSION OF TIME TO
FILE A MOTION TO AMEND THE RETURN OF SERVICE AND
STRIKE CERTAIN AFFIRMATIVE DEFENSES
Plaintiffs IHOP IP, LLC and International House of Pancakes, LLC move the Court for
an additional fourteen (14) days, up to and including Friday, January 27, 2012, in which to file
their Motion to Amend the Return of Service and Strike Certain Affirmative Defenses of The
Prayer Furnace, Inc. In support of this motion, plaintiffs state:
1.

Pursuant to Fed. R. Civ. P. 12(f), the deadline for filing a motion to strike is

currently Friday January 13, 2012.
2.

Plaintiffs and defendant The Prayer Furnace, Inc. are actively engaged in

settlement discussions.
3.

No prejudice to any party would result from plaintiffs being permitted additional

time to file its motion and the requested extension will not affect any other deadlines set out in
the Court's Scheduling Order [Doc. #31].
4.

No prior extensions of time have been requested or granted.

DB04/808085.0002/5593869.1PF06

5.

Plaintiffs have consulted with counsel for defendant regarding the extension, and

defendant has approved this request.
6.

For these reasons, plaintiffs respectfully requests that the Court grant its motion

for an extension of time.
Respectfully submitted,

/s/Elizabeth A. Tassi
Mark D. Hinderks (MO Bar No. 58124)
Mark M. Iba (MO Bar No. 45452)
Elizabeth A. Tassi (MO Bar No. 59621)
STINSON MORRISON HECKER LLP
1201 Walnut Street, Suite 2900
Kansas City, Missouri 64106
[phone] (telephone)
[phone] (facsimile)
Attorneys for Plaintiffs
INTERNATIONAL HOUSE OF PANCAKES,
LLC and IHOP IP, LLC
CERTIFICATE OF SERVICE

I hereby certify that on January 9, 2012, a true and correct copy of the foregoing
document was filed electronically via CM/ECF in the United States District Court for the
Western District of Missouri, with notice of same being electronically served by the Court,
addressed to:
Keith J. Grady
John M. Challis
POLSINELLI SHUGHART PC
100 S. Fourth Street, Suite 1000
St. Louis, MO 63102
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
[e-mail]
Lauren Tucker McCubbin
POLSINELLI SHUGHART PC
Twelve Wyandotte Plaza
120 West 12th Street, Suite 1800
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Kansas City, MO 64105
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Defendants
INTERNATIONAL HOUSE OF PRAYER,
FRIENDS OF THE BRIDEGROOM, INC.,
SHILOH MINISTRIES, INC., and MIKE BICKLE
Diane Waters
BENNETT, BODINE & WATERS, P.A.
11125 Johnson Drive
Shawnee, KS 66203
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
Attorney for Defendant
THE PRAYER FURNACE, INC.
d/b/a INTERNATIONAL HOUSE OF
PRATER EAST BAY
/s/Elizabeth A. Tassi
ATTORNEY FOR PLAINTIFFS

DB04/808085.0002/5593869.1PF06

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