Incentive Capital v. Camelot Entertainment Group et al

Filing 56

MOTION for Extension of Time to File Response/Reply as to 47 MOTION to Quash service pursuant to Rule 12(b)(5) filed by Plaintiff Incentive Capital. (Attachments: # 1 Text of Proposed Order) Motions referred to Samuel Alba.(Pia, Joseph)

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Joseph G. Pia (9945) Nathan S. Dorius (8977) PIA ANDERSON DORIUS REYNARD & MOSS 222 South Main Street, Suite 1800 Salt Lake City, Utah 84101 Telephone: (801) 350-9000 Facsimile: (801) 950-9010 E-mail: joe.pia@padrm.com nathan@padrm.com Attorneys for Plaintiff Incentive Capital, LLC IN THE UNITED STATES DISTRICT COURT DISTRICT OF UTAH, CENTRAL DIVISION INCENTIVE CAPITAL, LLC, a Utah Limited Liability Company, [PROPOSED] ORDER GRANTING PLAINTIFF’S MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANT PETER JAROWEY’S MOTION TO QUASH SERVICE Plaintiff, v. CAMELOT ENTERTAINMENT GROUP, INC., a Delaware Corporation; CAMELOT FILM GROUP, INC., a Nevada Corporation; CAMELOT DISTRIBUTION GROUP, INC., a Nevada Corporation, ROBERT P. ATWELL, an individual; JAMIE R. THOMPSON, an individual; STEVEN ISTOCK, an individual; TED BAER, an individual; PETER JAROWEY, an individual, Civil No. 2:11-cv-00288 Judge Paul Warner Defendants. Plaintiff Incentive Capital, LLC (“Plaintiff” or “Incentive”), by and through its counsel, hereby move, pursuant to DUCivR 77-2, for an order extending once, for fifteen (15) days, the time within which to respond to Defendant Peter Jarowey’s Motion to Quash Service (Docket No. 47) (“Jarowey’s Motion to Quash”). 1 Plaintiff Incentive Capital, LLC (“Plaintiff” or “Incentive”), by and through its counsel, has moved this Court, pursuant to DUCivR 77-2 on an ex parte basis, for a fifteen (15)-day extension of time – until June 24, 2011 – to respond to Defendant Peter Jarowey’s Motion to Quash Service (Docket No. 47) (“Jarowey’s Motion to Quash”). IT IS HEREBY ORDERED that the date for Plaintiff to respond to Jarowey’s Motion to Quash is extended from its original deadline of June 9, 2011 to June 24, 2011. DATED this ___ day of June 2011. BY THE COURT: ________________________________ Clerk of the Court 2 CERTIFICATE OF SERVICE I hereby certify that on this 15th day of June, 2011, I caused a true and correct copy of [PROPOSED] ORDER GRANTING PLAINTIFF’S MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANT PETER JAROWEY’S MOTION TO QUASH SERVICE to be filed with the Clerk of the Court using the CM/ECF system which served the following pursuant to Rules 5(b)(2)(D) and (E) of the Federal Rules of Civil Procedure: Dennis R. James Brian H. Hess MORGAN, MINNOCK, RICE & JAMES, L.C. Kearns Building, Eighth Floor 136 South Main Street Salt Lake City, Utah 84101 djames@mmrj.com Jonathan M. Levitan, Esq. LAW OFFICES OF JONATHAN MARK LEVITAN 12400 Wilshire Blvd., Suite 1300 Los Angeles, CA 90025 Michael O’Brien VANCOTT BAGLEY 36 S. State St., Suite 1900 Salt Lake City, UT 84111 Wayne G. Petty MOYLE & DRAPER, P.C. 175 East 400 South, No. 900 Salt Lake City, Utah 84111 /s/ Joseph Pia 3

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