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

Filing 9

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

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

Doc. 9

Case 2:06-cv-01469-JCC

Document 9

Filed 03/07/2007

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 RESPONSE TO ORDER TO SHOW CAUSE RE SERVICE OF PROCESS

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 process of service.

I.JUSTICE LAW, P.C.
1325 Fourth Ave., Suite 940 Seattle, WA 98101 Phone: [phone] Fax: [phone]

Dockets.Justia.com

Case 2:06-cv-01469-JCC

Document 9

Filed 03/07/2007

Page 2 of 2

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Plaintiffs have effected service upon the following defendants: Impulse Marketing Group, Inc., (on February 5, 2007); Jeffrey Goldstein, (on February 5, 2007); Kenneth Adamson, (on February 13, 2007), which affidavits of service have been filed with this Court. As to defendant Adamson, Plaintiffs acknowledge that service upon him was perfected several days beyond the 120 days provided in FRCP 4(m). Plaintiffs contends that good cause exists for any delays in service, as although diligence was exercised in attempting to have him served, Mr. Adamson was not readily available, and may have been attempting to avoid service, and therefore Plaintiffs request that the time for service under the rule be extended in order to allow personal service upon defendant Adamson to be effective. Plaintiffs have been unable to locate, and therefore has been unable to serve the following defendants within the time allowed by FRCP 4(m): Gregory Greenstein; Steven Wadley; both prior employees of defendant Impulse, who apparently no longer work there. Accordingly, Plaintiffs request that defendants Greenstein, and Wadley be dismissed without prejudice at this time. RESPECTFULLY submitted this 7th 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: [phone] Fax: [phone]