Powell's Books, Inc. et al v. Myers et al

Filing 41

Unopposed Motion for Extension of Time to File Supporting Material. Filed by all plaintiffs. (Runkles-Pearson, P.K.)

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Powell's Books, Inc. et al v. Myers et al Doc. 41 P.K. Runkles-Pearson, OSB No. 061911 pkrunkles-pearson@stoel.com STOEL RIVES LLP 900 SW Fifth Avenue, Suite 2600 Portland, OR 97204 Telephone: (503) 224-3380 Facsimile: (503) 220-2480 Michael A. Bamberger mbamberger@sonnenschein.com Rachel G. Balaban rbalaban@sonnenschein.com SONNENSCHEIN NATH & ROSENTHAL LLP 1221 Avenue of the Americas, 24th Floor New York, NY 10020 Telephone: (212) 768-6700 Facsimile: (212) 768-6800 Attorneys for Plaintiffs UNITED STATES DISTRICT COURT DISTRICT OF OREGON POWELL'S BOOKS, INC., et al., Plaintiffs, v. HARDY MYERS, in his official capacity as ATTORNEY GENERAL OF THE STATE OF OREGON, et al., Defendants. Civil No. CV 08-0501-MO PLAINTIFFS' UNOPPOSED MOTION TO ALLOW LATE FILING OF SUPPORTING MATERIAL Page 1 - PLAINTIFFS' UNOPPOSED MOTION TO ALLOW LATE FILING OF SUPPORTING MATERIAL Portlnd3-1636119.1 0099880-00578 Dockets.Justia.com LOCAL RULE 7.1(A) COMPLIANCE Plaintiffs have conferred with defendant on the subject of this motion, and defendant has no objection to the motion. MOTION Plaintiffs respectfully request that this Court allow them to file additional material supporting their Motion for a Declaration of Unconstitutionality and a Permanent Injunction by Friday, August 8, 2008. This Court set July 31, 2008, as the deadline for plaintiffs to file their motion. Plaintiffs have or will timely file their motion and supporting memorandum, but require more time to file additional supporting material. Plaintiffs anticipate that the additional material will include a declaration enclosing, as supporting exhibits, actual books, many of which are mentioned in plaintiffs' memorandum, and which plaintiffs contend would violate ORS 167.054 and ORS 167.057 if furnished to a minor in the manner proscribed therein. Plaintiffs believe that the inclusion of these books in the record will prove useful to the Court's decision on the motion and to the parties' argument of the issues involved. Defendants have graciously agreed not to oppose this motion and have represented that the late filing will not create a hardship affecting their timely response. //// //// //// //// //// //// //// //// //// Page 2 PLAINTIFFS' UNOPPOSED MOTION TO ALLOW LATE FILING OF SUPPORTING MATERIAL Portlnd3-1636119.1 0099880-00578 DATED: July 31, 2008. STOEL RIVES LLP s/ P.K. Runkles-Pearson_______________ P.K. RUNKLES-PEARSON, OSB NO. 061911 pkrunkles-pearson@stoel.com STOEL RIVES LLP 900 SW Fifth Avenue, Suite 2600 Portland, OR 97204 Telephone: (503) 224-3380 Facsimile: (503) 220-2480 Cooperating Attorney ACLU Foundation of Oregon Attorney for Plaintiffs MICHAEL A. BAMBERGER* mbamberger@sonnenschein.com RACHEL G. BALABAN* rbalaban@sonnenschein.com SONNENSCHEIN NATH & ROSENTHAL LLP 1221 Avenue of the Americas, 24th Floor New York, NY 10020 Telephone: (212) 768-6700 Facsimile: (212) 391-1247 * Application for pro hac vice admission filed Attorneys for Plaintiffs Page 3 - PLAINTIFFS' UNOPPOSED MOTION TO ALLOW LATE FILING OF SUPPORTING MATERIAL Portlnd3-1636119.1 0099880-00578

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