Faughn et al v. JPMorgan Chase Bank, NA

Filing 39

MOTION for leave to file Surreply to Defendants Motion to Claw Back Confidential Materials and Strike the Complaint filed by Rick D. Holtsclaw on behalf of All Plaintiffs. Suggestions in opposition/response due by 7/28/2014 unless otherwise directed by the court. (Holtsclaw, Rick)

IN THE UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF MISSOURI
WESTERN DIVISION
MARK FAUGHN, et al.,
Plaintiffs,
vs.
JPMORGAN CHASE BANK, N.A.,
Defendant.

)
)
)
)
)
)
)
)
)

Case No. 14-CV-00245-BCW

PLAINTIFFS’ UNOPPOSED MOTION FOR LEAVE TO FILE A SURREPLY TO DEFENDANT’S
MOTION TO CLAW BACK CONFIDENTIAL MATERIALS AND STRIKE THE COMPLAINT
COME NOW Plaintiffs, by and through counsel of record, and move the Court for leave
to file a surreply to Defendant’s Motion to Claw Back Confidential Materials and Strike the
Complaint. In support of their motion, Plaintiffs state as follows:
1.

Defendant has transmitted sealed documents from the SEC action against

Millennium Bank in Texas.
2.

The documents that were transmitted are highly relevant to the issues before

this Court in considering Defendant’s claw-back motion.
3.

The documents from the SEC action were transmitted after Plaintiffs’

suggestions in opposition to the claw-back motion were filed.
4.

Plaintiffs request leave to file a surreply, not to exceed six pages, for the purpose

of briefly addressing the documents from the SEC action which were not available to Plaintiffs
when their opposition was filed.
5.

Counsel for Plaintiffs has conferred with counsel for Defendant, and counsel for

Defendant has indicated that Defendant does not oppose this motion.

WHEREFORE, for the foregoing reasons, Plaintiffs respectfully request that this Court
grant Plaintiffs leave to file a surreply to Defendant’s Motion to Claw Back Confidential
Materials and Strike the Complaint.

Respectfully submitted,
/s/ Rick D. Holtsclaw
Rick D. Holtsclaw, MO #32866
HOLTSCLAW FIRM
2029 Wyandotte, Suite 100
Kansas City, Missouri 64108
Telephone: [phone]
Facsimile: [phone]
[e-mail]
ATTORNEY FOR PLAINTIFFS

CERTIFICATE OF SERVICE
I certify that on this 9th day of July, 2014, I filed the above and foregoing electronically
with CM/ECF, which will automatically transmit a copy of this document to Defendant’s counsel
of record.
/s/ Rick D. Holtsclaw
Attorney for Plaintiffs

2