United States of America v. Impulse Media Group Inc

Filing 34

Joint MOTION for Extension of Time on Pretrial Order Deadlines by Plaintiff United States of America. Noting Date 10/16/2006. (Attachments: # 1 Proposed Order)(Hash, Lauren)

United States of America v. Impulse Media Group Inc

Doc. 34

Case 2:05-cv-01285-RSL

Document 34

Filed 10/16/2006

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JOINT MOTION FOR LEAVE TO EXTEND PRETRIAL ORDER DEADLINES CV05-1285L Department of Justice P.O. Box 386 Washington, DC 20044 [phone]

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE UNITED STATES OF AMERICA, Plaintiff, v. IMPULSE MEDIA GROUP, INC., a Washington corporation, Defendant. NOTE ON MOTION CALENDAR: October 16, 2006

No. CV05-1285L JOINT MOTION FOR LEAVE TO EXTEND PRETRIAL ORDER DEADLINES

Plaintiff United States of America and Defendant Impulse Media Group, Inc., by and through their undersigned counsel, hereby file this Joint Motion for Leave to Extend Pretrial Order Deadlines. The scheduling order entered by the Court (Docket # 7) requires the parties to mediate the case pursuant to CR 39.1(c)(3) by November 4, 2006. The scheduling order also requires the parties to submit an agreed pretrial order by November 22, 2006, and trial briefs, proposed voir dire questions, proposed jury instructions, and trial exhibits by November 29, 2006. The parties have fully briefed Cross-Motions for Summary Judgment in this case. Consequently, Plaintiff and Defendant seek to extend the mediation deadline from November 4, 2006, to thirty days after the Court has ruled on the pending Cross-Motions for Summary Judgment. The parties also request that the remaining deadlines set forth in the scheduling order be deferred until after the Court rules on the pending Cross-Motions for Summary Judgment and

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Dockets.Justia.com

Case 2:05-cv-01285-RSL

Document 34

Filed 10/16/2006

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that the parties be given forty-five days after such ruling to jointly propose new deadlines for these events. Dated: October 16, 2006

CarpeLaw PLLC s/ Robert S. Apgood Pro Hac Vice 2400 NW 80th Street #130 Seattle, WA 98117-4449 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail]

Lauren E. Hash s/ Lauren E. Hash Trial Attorney Department of Justice Office of Consumer Litigation P.O. Box 386 Washington, D.C. 20044 Tel: [phone] Fax: [phone] [e-mail]

JOINT MOTION FOR LEAVE TO EXTEND PRETRIAL ORDER DEADLINES CV05-1285L

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Department of Justice P.O. Box 386 Washington, DC 20044 [phone]