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)

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: [phone]
Facsimile: [phone]
E-mail: [e-mail]
[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
[e-mail]
[e-mail]
Jonathan M. Levitan
[e-mail]
Wayne G. Petty
MOYLE & DRAPER, P.C.
[e-mail]
Marc E. Kasowitz
David J. Shapiro
KASOWITZ, BENSON, TORRES & FRIEDMAN LLP
[e-mail]
[e-mail]

By: /s/ Joseph Pia

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