Gordon v. Impulse Marketing Group Inc

Filing 549

MEMORANDUM in Support re 541 MOTION for Extension of Time to File Defendants' Reply for Defendants' Motion to Dismiss filed by all defendants. (Ivey, Floyd)

Gordon v. Impulse Marketing Group Inc

Doc. 549

Case 2:04-cv-05125-FVS

Document 549

Filed 09/28/2007

1

Hon. Fred Van Sickle

FLOYD E. IVEY Liebler, Ivey, Connor, Berry & St. Hilaire 3 P. O. Box 6125 Kennewick, WA 99336-0125 4 509-735-3581 Local Counsel for Defendants Impulse Marketing Group, Inc., 5 Jeffrey Goldstein, Phillip Huston and Kenneth Adamson
2

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Klein Zelman Rothermel LLP By: Sean Moynihan, Esq. 7 485 Madison Avenue New York, New York 10022 8 Telephone Number [phone] Facsimile Number [phone] 9 Attorneys for Defendants Impulse Marketing Group, Inc., Jeffrey Goldstein, Phillip Huston and Kenneth Adamson
6

ROBERT SIEGEL Attorney At Law Attorney for Plaintiff UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF WASHINGTON ) ) Plaintiff, ) vs. ) ) IMPULSE MARKETING GROUP, ) INC., ) ) Defendant ) ______________________________ ) ) IMPULSE MARKETING GROUP, ) INC., ) ) Third-Party Plaintiff, ) vs. ) ) BONNIE GORDON, et al., ) ) Third-Party Defendants. ) JAMES S. GORDON, JR., No. CV-04-5125-FVS DEFENDANTS' MEMORANDUM OF AUTHORITIES RE: MOTION FOR E X T E N S I O N OF TIME FOR DEFENDANTS TO FILE REPLY TO P L A I N T I F F ' S RESPONSE RE: D E F E N D A N T S ' MOTION TO DISMISS WITHOUT ORAL ARGUMENT

MEMORANDUM OF AUTHORITIES RE: EXTENSION OF TIME FOR DEFENDANTS TO FILE REPLY RE: DEFENDANTS' MOTION TO DISMISS
Memorandum re: Extension to File Reply - Page 1 of 3
LIEBLER, IVEY, CONNOR, BERRY & ST. HILAIRE

Attorneys at Law P.O. Box 6125 Kennewick, Washington 99336-0125 [phone]

Dockets.Justia.com

Case 2:04-cv-05125-FVS

Document 549

Filed 09/28/2007

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

On September 28, 2007 I discovered that Defendants' Motion for an Extension was filed with two Notices of Hearing with one named "MEMORANDUM". I now file the Memorandum. Also, on September 28, 2007 I have received email from attorney Mr. Siegel advising that Plaintiff does not resist Defendants' request for an Extension of time. Prior to filing the Motion for Extension I attempted, several times by email and telephone to reach Mr. Siegel without success. Mr. Siegel advises that he has been out of communication and did not receive the notes until September 28, 2007. The Defendants' Motion for withdrawal of counsel Stacy K. Wolery was filed September 25, 2007. Ms. Wolery is no longer with the firm of Klein Zelman Rothermel LLP. Ms. Wolery was significantly involved in preparing Defendants' Motion to Dismiss. Plaintiff has Responded. Defendants' Reply is due Friday, September 28, 2007. With scheduling conflicts and with the need for file review, it will be a burden for Defendant counsel to provide Defendants' Reply by September 28, 2007. The Defendants request an extension of time within which to provide the Defendants' Reply to Plaintiff's Response to October 12, 2007. The hearing of this Motion to Dismiss is set for October 22, 2007. This Motion is brought in accordance with LR 7.1(h)(6). Dated: September 28, 2007

LIEBLER, IVEY, CONNOR, BERRY & ST. HILAIRE s/ FLOYD E. IVEY Floyd E. Ivey, WSBA #6888 Attorneys for the Defendant Impulse

Memorandum re: Extension to File Reply - Page 2 of 3

LIEBLER, IVEY, CONNOR, BERRY & ST. HILAIRE

Attorneys at Law P.O. Box 6125 Kennewick, Washington 99336-0125 [phone]

Case 2:04-cv-05125-FVS

Document 549

Filed 09/28/2007

I hereby certify that on September 28, 2007, I electronically filed Defendants' Memorandum of Authorities regarding Defendants' Motion for an Extension of 2 Time to File Reply with the Clerk of the Court using the CM/ECF System which will send notification of such filing to Robert Siegel and Sean A. Moynihan. I hereby 3 certify that I have served the foregoing to the following non-CM/ECF participants by other means: Bonnie Gordon, Jonathan Gordon, James S. Gordon, III, Robert 4 Pritchett, Emily Abbey and Jamila Gordon.
1 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Memorandum re: Extension to File Reply - Page 3 of 3
LIEBLER, IVEY, CONNOR, BERRY & ST. HILAIRE

S/ FLOYD E. IVEY FLOYD E. IVEY

Attorneys at Law P.O. Box 6125 Kennewick, Washington 99336-0125 [phone]