Omni Innovations LLC et al v. Impulse Marketing Group Inc et al

Filing 10

RESPONSE TO ORDER TO SHOW CAUSE by Plaintiff Omni Innovations LLC. (Siegel, Robert)

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Omni Innovations LLC et al v. Impulse Marketing Group Inc et al Doc. 10 Case 2:06-cv-01469-JCC Document 10 Filed 03/27/2007 Page 1 of 2 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 PLAINTIFF'S RESPONSE TO ORDER TO SHOW CAUSE RE SERVICE OF PROCESS -1 v. IMPULSE MARKETING GROUP, INC, a Nevada/Georgia corporation; JEFFREY GOLDSTEIN, individually and as part of his marital community; KENNETH ADAMSON, individually and as part of his marital community; JOHN DOES, I-X, Defendants, i.Justice Law, PC 1325 Fourth Ave., Suite 940 Seattle, WA 98101-2509 206-304-5400 THE HON. MARSHA J. PECHMAN UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON, SEATTLE OMNI INNOVATIONS, LLC, a Washington Limited Liability company; EMILY ABBEY, an individual, Plaintiffs, NO. 06-1469 P PLAINTIFF'S SUPPLEMENTAL RESPONSE TO ORDER TO SHOW CAUSE RE FILING OF JSR Plaintiffs Omni Innovations, LLC., and Emily Abbey, by and through their undersigned counsel, respond as follows to this Court's Order To Show Cause of March 1, 2007 re the filing of a Joint Status Report. I.JUSTICE LAW, P.C. 1325 Fourth Ave., Suite 940 Seattle, WA 98101 Phone: 206-304-5400 Fax: 206-624-0717 Dockets.Justia.com Case 2:06-cv-01469-JCC Document 10 Filed 03/27/2007 Page 2 of 2 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 As noted in Plaintiffs' initial Response to the Order To Show Cause, Plaintiffs have effected service upon 3 of the defendants, which affidavits of service have been filed with this Court. The statutory period for Answering the Complaint for these out-of-state defendants is 60 days from the date of service. Thus, April 5th and 13th would be the operative dates for the defendants served. None of the defendants have appeared or answered to date. Consequently, Plaintiff has been thus far unable to comply with the deadlines pursuant to FRCP 26, including the filing of a Joint Status Report, as no parties have yet appeared. Accordingly, Plaintiff respectfully requests an extension until April 30, 2007 to file the JSR, or move for default in the event that a defendant fails to appear or answer. RESPECTFULLY submitted this 27th day of March, 2007. i.Justice Law, PC /s/ Robert J. Siegel By: Robert J. Siegel, WSBA #17312 i.Justice Law, PC 1325 Fourth Ave., Suite 940 Seattle, WA 98101-2509 PLAINTIFF'S RESPONSE TO ORDER TO SHOW CAUSE RE SERVICE OF PROCESS -2 I.JUSTICE LAW, P.C. 1325 Fourth Ave., Suite 940 Seattle, WA 98101 Phone: 206-304-5400 Fax: 206-624-0717

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