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

Filing 50

MOTION for Extension of Time to File Response/Reply to Plaintiff's Opposition to ABA's Motion to Dismiss 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.

)
)
)
)
)
)
)
)
)
)

Case No.

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

DEFENDANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE A
REPLY TO PLAINTIFF’S MEMORANDUM IN OPPOSITION TO DEFENDANT’S
MOTION TO DISMISS
Comes now the defendant, American Bar Association (“ABA”), by and through counsel,
and respectfully moves this Honorable Court for an additional seven (7) days beyond the
deadline of March 12, 2012, up to and including March 19, 2012, to file a reply to the plaintiff’s
opposition [Doc. 48] to defendant’s motion to dismiss [Doc. 43]. As grounds for this motion, the
defendant relies upon the contemporaneously filed memorandum of law.
WHEREFORE, the defendant respectfully requests that the Court grant an extension of
time to file its reply to the plaintiff’s opposition to its motion to dismiss.
Respectfully submitted, this 5th day of March, 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

CERTIFICATE OF SERVICE
I hereby certify that on the 5th Day of March, 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]

2