Incentive Capital v. Camelot Entertainment Group et al

Filing 83

MOTION for Leave to File Opposition to Motion to Dismiss today 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: Attorneys for Plaintiffs IN THE UNITED STATES DISTRICT COURT DISTRICT OF UTAH, CENTRAL DIVISION INCENTIVE CAPITAL, LLC, a Utah Limited Liability Company, MOTION TO PERMIT FILING OF OPPOSITION TO MOTION TO DISMISS TODAY 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-CW Judge Clark Waddoups Defendants. 1   Pursuant to Rule 6(b) of the Federal Rules of Civil Procedure, Plaintiff Incentive Capital, LLC (“Plaintiff” or “Incentive”), by and through its counsel, respectfully files this Motion to Permit Filing of its Opposition to Motion to Dismiss Today for the reasons set forth in the accompanying Memorandum. DATED this 5th day of August, 2011. PIA ANDERSON DORIUS REYNARD & MOSS /s/ Joseph Pia Joseph Pia Attorneys for Plaintiff 2   CERTIFICATE OF SERVICE I hereby certify that on this 5th day of August, 2011, a true and correct copy of forgoing MOTION TO PERMIT FILING OF OPPOSITION TO MOTION TO DISMISS TODAY was served by electronic mail on the following: John A. Snow Karen E. O’Brien VAN COTT BAGLEY CORNALL & McCARTHY Jonathan M. Levitan Wayne G. Petty MOYLE & DRAPER, P.C. Marc E. Kasowitz David J. Shapiro KASOWITZ, BENSON, TORRES & FRIEDMAN LLP By: /s/ Joseph Pia 3  

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