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  • Steinbuch v. Cutler Et Al - Document No. 46

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    MOTION for Extension of Time to File Response/Reply as to 38 MOTION to Dismiss for Lack of Jurisdiction, 44 MOTION to Dismiss, 36 Corporate Disclosure Statement (Rule 7.1), 43 Corporate Disclosure Statement (Rule 7.1), 45 Brief in Support, 37 Corporate Disclosure Statement (Rule 7.1), Addendum, 39 Brief in Support, 41 Brief in Support, 40 MOTION to Dismiss for Lack of Jurisdiction, 42 Corporate Disclosure Statement (Rule 7.1) by Robert Steinbuch. (Attachments: # 1 Exhibit Plaintiff's Consent to Disney-Hyperion# 2 Exhibit Plaintiff's Consent to HBO-Time-Warner# 3 Exhibit Sample Order)(Rosen, Jonathan) 4:2006cv00620 Arkansas Eastern District Court

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    Steinbuch v. Cutler et al - Document No. 46

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    MOTION for Extension of Time to File Response/Reply as to 38 MOTION to Dismiss for Lack of Jurisdiction, 44 MOTION to Dismiss, 36 Corporate Disclosure Statement (Rule 7.1), 43 Corporate Disclosure Statement (Rule 7.1), 45 Brief in Support, 37 Corporate Disclosure Statement (Rule 7.1), Addendum, 39 Brief in Support, 41 Brief in Support, 40 MOTION to Dismiss for Lack of Jurisdiction, 42 Corporate Disclosure Statement (Rule 7.1) by Robert Steinbuch. (Attachments: # 1 Exhibit Plaintiff's Consent to Disney-Hyperion# 2 Exhibit Plaintiff's Consent to HBO-Time-Warner# 3 Exhibit Sample Order)(Rosen, Jonathan) 4:2006cv00620 Arkansas Eastern District Court

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    10 views3 pages

    Steinbuch v. Cutler Et Al - Document No. 46

    Uploaded by

    Justia.com
    MOTION for Extension of Time to File Response/Reply as to 38 MOTION to Dismiss for Lack of Jurisdiction, 44 MOTION to Dismiss, 36 Corporate Disclosure Statement (Rule 7.1), 43 Corporate Disclosure Statement (Rule 7.1), 45 Brief in Support, 37 Corporate Disclosure Statement (Rule 7.1), Addendum, 39 Brief in Support, 41 Brief in Support, 40 MOTION to Dismiss for Lack of Jurisdiction, 42 Corporate Disclosure Statement (Rule 7.1) by Robert Steinbuch. (Attachments: # 1 Exhibit Plaintiff's Consent to Disney-Hyperion# 2 Exhibit Plaintiff's Consent to HBO-Time-Warner# 3 Exhibit Sample Order)(Rosen, Jonathan) 4:2006cv00620 Arkansas Eastern District Court

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    Steinbuch v. Cutler et al Doc.

    46
    Case 4:06-cv-00620-WRW Document 46 Filed 08/22/2006 Page 1 of 3

    UNITED STATES DISTRICT COURT


    FOR THE EASTERN DISTRICT OF ARKANSAS
    -----------------------------------------------------------
    Robert Steinbuch : Index No.: 4-06 CV0000 620WRW
    Plaintiff, :
    :
    -v- :
    :
    Jessica Cutler & Hyperion Books & Disney :
    Publishing Worldwide & Home Box Office & :
    Time Warner :
    Defendants. :
    -----------------------------------------------------------

    PLAINTIFF’S MOTION FOR AN


    EXTENSION OF TIME UNTIL NOVEMBER 15, 2006
    TO FILE RESPONSE TO DEFENDANTS’ MOTIONS TO DISMISS

    Plaintiff law professor Robert Steinbuch moves this Court for an extension of

    time, up to and including November 15, 2006, to file his responses to Defendants’ Cutler,

    Hyperion Books, Disney Publishing Worldwide, Home Box Office, and Time Warner

    Motions to Dismiss.

    On August 18, 2006 all five Defendants, Cutler, Hyperion Books, Disney

    Publishing Worldwide, Home Box Office, and Time Warner, filed Motions to Dismiss.

    Plaintiff’s counsel is a sole practitioner. All of the Defendants are represented by

    large law firms. There are eight attorneys of record for the Defendants, in addition to the

    extensive resources of their respective law firms. One lawyer is counsel for plaintiff.

    Given Counsel for Plaintiff’s workload, this Motion is not made for delay or for any other

    improper purpose, and good cause exists for extending the time to file Plaintiff’s

    response.

    When the Defendants requested that Plaintiff’s Counsel consent to an extension of

    time to file a response to the Complaint filed in this action, he, of course, as a matter of

    Dockets.Justia.com
    Case 4:06-cv-00620-WRW Document 46 Filed 08/22/2006 Page 2 of 3

    professional courtesy graciously granted the Defendants’ requests. See attached Exhibits

    A and B. It is unfortunate that neither Counsel for Defendants Cutler, Hyperion, and

    Disney nor Counsel for Defendants Home Box Office and Time Warner would

    reciprocate that professional courtesy and consent to Plaintiff’s similar request.1

    Given that the Motions to Dismiss is a potentially dispositive motion, that all five

    Defendants moved to dismiss, and that the Plaintiff’s Counsel is a sole practitioner,

    Plaintiff law professor Robert Steinbuch moves this Court for an extension of time, up to

    and including November 15, 2006, to file his responses to Defendants’ Cutler, Hyperion

    Books, Disney Publishing Worldwide, Home Box Office, and Time Warner Motions to

    Dismiss.

    Dated: August 22, 2006

    _/s/ Jonathan Rosen


    Jonathan Rosen, Esq.
    1645 Lamington Rd.
    Bedminster, NJ 07921
    (908) 759-1116
    Attorney for Plaintiff

    1
    Counsel for Defendants Cutler, Hyperion Books, Disney would not grant their consent
    to this request unless Plaintiff submitted to Defendant’s extortionary demands to waive
    his rights to discovery. Counsel for Defendants Home Box Office and Time Warner
    would only consent to a 40 day extension and made similar extortionary demands for any
    time thereafter.
    Case 4:06-cv-00620-WRW Document 46 Filed 08/22/2006 Page 3 of 3

    IN THE UNITED STATES DISTRICT COURT


    FOR THE EASTERN DISTRICT OF ARKANSAS

    CERTIFICATE OF SERVICE

    I hereby certify that on August 22, 2006, I presented the foregoing to the Clerk of Court
    for filing and uploading to the CM/ECF system, which shall send notification of such
    filing to the following:

    Philip S. Anderson psa@williamsanderson.com, mroach@williamsanderson.com;


    bwalton@williamsanderson.com

    Jess L. Askew , III jaskew@williamsanderson.com,


    eperryman@williamsanderson.com; ssmith@williamsanderson.com

    Beth M. Deere bdeere@williamsanderson.com, fdavis@williamsanderson.com

    Gary D. Marts , Jr. gmarts@wlj.com, rmoles@wlj.com

    Claire Hancock chancock@wlj.com

    Jonathan S. Rosen xjonathan@mac.com

    Clayborne S. Stone cstone@williamsanderson.com

    _/s/ Jonathan Rosen


    Jonathan Rosen, Esq.
    1645 Lamington Rd.
    Bedminster, NJ 07921
    (908) 759-1116
    Attorney for Plaintiff

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