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

Filing 27

MOTION to Stay by Plaintiff Omni Innovations LLC. (Attachments: # 1 Proposed Order)Noting Date 9/14/2007.(Siegel, Robert)

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

Doc. 27

Case 2:06-cv-01469-JCC

Document 27

Filed 08/27/2007

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Douglas E. McKinley, Jr. PO Box 202 Richland WA, 99352 [phone] i.Justice Law, P.C. Robert J. Siegel PO Box 258217 Seattle, WA 98165-1317

THE HON. JOHN C. COUGHENOUR

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON, SEATTLE OMNI INNOVATIONS, LLC, a Washington Limited Liability company, Plaintiff, 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; GREGORY GREENSTEIN, individually and as part of his marital community; STEVE WADLEY, individually and as part of his marital community; JOHN DOES, I-X, NOTE FOR HEARING: SEPT. 14, 2007 NO. 06-1469 MOTION FOR A STAY

Defendants, Plaintiff, by and through undersigned counsel, hereby moves the Court for an order staying this litigation pending Plaintiffs' appeal to the US Circuit Court of Appeals For the Ninth Circuit in Gordon v Virtumundo, et al., CV06-0204. Plaintiffs have filed an appeal to the US Court of Appeals for the Ninth Circuit in MOTION FOR A STAY -1
i.Justice Law, PC
PO Box 25817 Seattle, WA 98165-1317 Phone/Fax: [phone]

Dockets.Justia.com

Case 2:06-cv-01469-JCC

Document 27

Filed 08/27/2007

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Virtumundo. Although some of the factual issues in the present case differ from those in Virtumundo, the fundamental issue of Plaintiffs' standing is common, and critical to both cases. Additionally, Plaintiff's counsel has filed a motion to withdraw, and a stay would serve to protect Plaintiff's rights pending the Virtumundo appeal, and provide Plaintiff adequate time within which to secure substitute counsel. Accordingly, there is good cause to stay this litigation to preserve judicial economy as well as the resources of the parties hereto. RESPECTFULLY SUBMITTED this 27th day of August, 2007.

DOUGLAS E. MCKINLEY, JR Attorney at Law /S/ Douglas E. McKinley, Jr. Douglas E. McKinley, Jr., WSBA #20806 Attorney for Plaintiffs

i.Justice Law, P.C. /S/ Robert J. Siegel Robert J. Siegel, WSBA #17312 Attorney for Plaintiffs

MOTION FOR A STAY -2

i.Justice Law, PC
PO Box 25817 Seattle, WA 98165-1317 Phone/Fax: [phone]

Case 2:06-cv-01469-JCC

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Filed 08/27/2007

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i.Justice Law, PC
PO Box 25817 Seattle, WA 98165-1317 Phone/Fax: [phone]

Certificate of Service

I, hereby, certify that on August 27, 2007, I filed the attached pleading with this Court via approved electronic filing, which will serve all counsel for defendants. i.Justice Law, PC 1325 Fourth Ave., Suite 940 Seattle, WA 98101 /s/ Robert J. Siegel Attorneys for Plaintiffs.