Filed: Oct. 10, 2016
Latest Update: Oct. 10, 2016
Summary: STIPULATION AND (PROPOSED) ORDER FOR EXTENSION OF TIME FOR PLAINTIFF TO FILE AN OPPOSITION TO DEFENDANTS' MOTION TO DISMISS FOR: (1) LACK OF PERSONAL JURISDICTION, (2) FAILURE TO JOIN A NECESSARY PARTY, (3) IMPROPER VENUE, AND (4) REQUEST TO TRANSFER VENUE (Second Request) RICHARD F. BOULWARE, II , Magistrate Judge . Plaintiff THE HACKETT MILLER COMPANY, INC. and Defendants GFOUR PRODUCTIONS, LLC and SPOTLIGHT RIGHTS LLC, by and through their undersigned counsel, hereby stipulate and agree
Summary: STIPULATION AND (PROPOSED) ORDER FOR EXTENSION OF TIME FOR PLAINTIFF TO FILE AN OPPOSITION TO DEFENDANTS' MOTION TO DISMISS FOR: (1) LACK OF PERSONAL JURISDICTION, (2) FAILURE TO JOIN A NECESSARY PARTY, (3) IMPROPER VENUE, AND (4) REQUEST TO TRANSFER VENUE (Second Request) RICHARD F. BOULWARE, II , Magistrate Judge . Plaintiff THE HACKETT MILLER COMPANY, INC. and Defendants GFOUR PRODUCTIONS, LLC and SPOTLIGHT RIGHTS LLC, by and through their undersigned counsel, hereby stipulate and agree ..
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STIPULATION AND (PROPOSED) ORDER FOR EXTENSION OF TIME FOR PLAINTIFF TO FILE AN OPPOSITION TO DEFENDANTS' MOTION TO DISMISS FOR: (1) LACK OF PERSONAL JURISDICTION, (2) FAILURE TO JOIN A NECESSARY PARTY, (3) IMPROPER VENUE, AND (4) REQUEST TO TRANSFER VENUE
(Second Request)
RICHARD F. BOULWARE, II, Magistrate Judge.
Plaintiff THE HACKETT MILLER COMPANY, INC. and Defendants GFOUR PRODUCTIONS, LLC and SPOTLIGHT RIGHTS LLC, by and through their undersigned counsel, hereby stipulate and agree to an 15-day extension of time up to and including September 30, 2016, for Plaintiff to file an Opposition to Defendants' Motion to Dismiss for: (1) Lack of Personal Jurisdiction, (2) Failure to Join a Necessary Party, (3) Improper Venue, and (4) Request to Transfer Venue in the above-captioned matter (ECF No. 22) ("Motion to Dismiss").
Defendant's Motion to Dismiss was filed on August 29, 2016. On September 13, 2016, the parties filed a Stipulation giving Plaintiff a 15-day extension of time to file an Opposition to Defendants' Motion to Dismiss (ECF No. 23) (the "First Extension Request") which extended the original deadline for Plaintiff's Opposition to Defendants' Motion to Dismiss to September 30, 2016. The Court has not yet signed the First Extension Request.
By and through this Stipulation, the parties agree to extend the deadline for Plaintiff to file Plaintiff's Opposition to Defendants' Motion to Dismiss to October 17, 2016. This is Plaintiff's second request for an extension of time for Plaintiff to file an Opposition to Defendants' Motion to Dismiss. Plaintiff requests an extension of time to file an Opposition to Defendants' Motion to Dismiss in order to avoid unfairly prejudicing Plaintiff in this matter. Plaintiff's counsel is presently scheduled to appear for a jury trial commencing October 3rd and continuing through October 7, 2016. Given the necessity of devoting full attention to the trial and final preparations for the same, absent the brief extension requested, Plaintiff's counsel will be unable to competently and fully address the complex jurisdictional and venue issues raised in Defendants' Motion to Dismiss, thus unfairly prejudicing Plaintiff in this matter. Defendants, through this stipulation, have agreed to Plaintiff's requested extension under the circumstances.
For these reasons, this Request is made for good cause and not for purposes of delay.
IT IS SO ORDERED.
