craigslist Inc v. McMaster et al

Filing 16

MOTION for Extension of Time to respond to Defendants' Motion to Dismiss by craigslist Inc. Response to Motion due by 8/17/2009 No proposed order(Griffith, Joseph)

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA CHARLESTON DIVISION craigslist, Inc., Plaintiff, v. HENRY D. McMASTER, in his official capacity as ATTORNEY GENERAL OF THE STATE OF SOUTH CAROLINA, et al., Defendants. Joseph P. Griffith, Jr. (Fed. ID # 2473) Joe Griffith Law Firm, LLC Seven State Street Charleston, S.C. 29401 843.225.5563 (tel) 843.722.6254 (fax) joegriffithjr@hotmail.com Counsel for craigslist, Inc. PLAINTIFF'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO RESPOND TO DEFENDANTS' MOTION TO DISMISS Plaintiff craigslist, Inc., ("craigslist"), pursuant to Rule 6(b) of the Federal Rules of Civil Procedure and Rule 6.01 of the Local Civil Rules DSC, hereby moves for an enlargement of time in which to respond to the Defendants' motion to dismiss. In support thereof, craigslist respectfully states as follows: 1. The current deadline for craigslist to respond to the Defendants' motion to dismiss Civil Action No. 2:09-1308-CWH is August 10, 2009, pursuant to Rule 7.06 of the Local Civil Rules DSC. Page 1 of 3 2009-7-30.rule 6.p's motion to enlarge time to respond to mtd 2. 3. This deadline has not previously been extended. craigslist requests an additional twenty-one (21) days in which to respond to the motion to dismiss. The proposed new deadline is August 31, 2009. 4. The proposed extension should not affect other deadlines as no scheduling order has been issued. 5. craigslist requests an extension of time to respond to the Defendants' motion to dismiss due to heavy case load of counsel and counsel's long-standing vacation plans. Of note, craigslist did not oppose Defendants' requested extension of time to file a response to the Complaint. Defendants were allowed two months to respond to craigslist's Complaint (craigslist filed its lawsuit on May 20, 2009 and Defendants accepted service on May 22, 2009; Defendants were allowed until July 22, 2009 to answer or otherwise plead). 6. Pursuant to Local Rule 7.02 DSC, the undersigned has consulted with Defendants' counsel and said counsel does not oppose this motion. 7. Pursuant to Local Civil Rule 7.04, DSC, no memorandum is filed herewith as this motion is self-explanatory. Page 2 of 3 2009-7-30.rule 6.p's motion to enlarge time to respond to mtd Respectfully submitted, This the 30th day of July, 2009. /s/ Joseph P. Griffith, Jr. By:_____________________________ Joseph P. Griffith, Jr., Esquire Joe Griffith Law Firm, LLC Federal ID No. 2473 South Carolina Bar No. 2292 7 State Street Charleston, South Carolina 29401 (843) 225-5563 (Telephone) (843) 722-6254 (Facsimile) joegriffithjr@hotmail.com Counsel for craigslist, Inc. CERTIFICATE OF SERVICE The undersigned hereby certifies that a copy of the foregoing PLAINTIFF'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO RESPOND TO DEFENDANTS' MOTION TO DISMISS was served on this date upon the following electronically and/or by depositing a true copy of same in the United States Mail, postage prepaid, addressed as follows: Robert D. Cook Assistant Deputy Attorney General AGRCOOK@SCAG.GOV J. Emory Smith, Jr. Assistant Deputy Attorney General AGESMITH@SCAG.GOV Deborah R.J. Shupe Assistant Attorney General DSHUPE@SCAG.GOV P.O. Box 11549 Columbia, S.C. 29211 This the 30th day of July, 2009. /s/ Joseph P. Griffith, Jr. ______________________________ Joseph P. Griffith, Jr. Page 3 of 3 2009-7-30.rule 6.p's motion to enlarge time to respond to mtd

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