Lincoln Memorial University Duncan School of Law v. American Bar Association (TV1)

Filing 23

MEMORANDUM in Support of Motion re 22 MOTION for Extension of Time to File Answer , Motion to Dismiss, or other Responsive Motion or Pleading filed by American Bar Association. (Vogel, P)

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF TENNESSEE
KNOXVILLE DIVISION
LINCOLN MEMORIAL UNIVERSITY
DUNCAN SCHOOL OF LAW,
Plaintiff,
v.
THE AMERICAN BAR ASSOCIATION,
Defendant.

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Case No.

3:11-CV-608
(Varlan/Shirley)

MEMORANDUM IN SUPPORT OF MOTION FOR EXTENSION OF TIME TO
RESPOND TO PLAINTIFF’S COMPLAINT
The American Bar Association (“ABA”), by and through counsel, respectfully moves this
Honorable Court for an additional twenty-one (21) days beyond the deadline of January 18,
2012, up to and including February 8, 2012, to respond to plaintiff’s Complaint.
For cause, the defendant would show to the court that the plaintiff’s Verified Complaint
(Doc. 1) contains one hundred and twenty-six (126) allegations, comprising of nearly forty (40)
pages. Said Complaint was filed in the midst of the holiday season. Further, the defendant would
show that it has the plaintiff’s Motion for Temporary Restraining Order (Doc. 2) pending for
which it has spent considerable time and effort responding to same. The Motion for Temporary
Restraining Order is set for hearing this Friday, January 6, 2012. Finally, counsel for the
defendant contacted counsel for the plaintiff requesting that the parties enter into a stipulation of
the twenty-one (21) day extension, pursuant to Local Rule 12.1, but plaintiff’s counsel declined
to agree.
WHEREFORE, the defendant respectfully requests that the Court grant an extension of
time to respond to plaintiff’s Complaint.
Respectfully submitted, this 4th day of January, 2012.

s/ P. Alexander Vogel
HOWARD H. VOGEL, BPR NO. 1015
JEFFREY R. THOMPSON, BPR NO. 20310
P. ALEXANDER VOGEL, BPR NO. 23944
O’NEIL, PARKER & WILLIAMSON, PLLC
7610 Gleason Drive, Suite 200
Knoxville, Tennessee 37919
[phone] (telephone)
[phone] (facsimile)
[e-mail]
[e-mail]
[e-mail]
Patricia J. Larson
Stephanie Giggetts
AMERICAN BAR ASSOCIATION
321 North Clark Street
Chicago, Illinois 60654
[phone]
Anne E. Rea
Michael P. Doss
Linda R. Friedlieb
SIDLEY AUSTIN, LLP
One South Dearborn Street
Chicago, Illinois 60603
[phone]
Attorneys for the Defendant The American Bar
Association

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CERTIFICATE OF SERVICE
I hereby certify that on the 4th Day of January, 2012, I caused to be filed electronically a
copy of the foregoing pleading. The Court’s electronic filing system will send notice of this
filing to all parties indicated on the electronic filing receipt. I will cause all other parties to be
served by regular U.S. mail. Parties may access this filing through the Court’s electronic filing
system.
s/ P. Alexander Vogel
HOWARD H. VOGEL, BPR NO. 1015
JEFFREY R. THOMPSON, BPR NO. 20310
P. ALEXANDER VOGEL, BPR NO. 23944
O’NEIL, PARKER & WILLIAMSON, PLLC
7610 Gleason Drive, Suite 200
Knoxville, Tennessee 37919
[phone] (telephone)
[phone] (facsimile)
[e-mail]
[e-mail]
[e-mail]

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