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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TENNESSEE
`WESTERN DIVISION
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`B.E. TECHNOLOGY, L.L.C.,
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`CIV. A. NO. 2:12-cv-02833-JPM
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`v.
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`PEOPLE MEDIA, INC.
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`PLAINTIFF,
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`DEFENDANT.
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`DEFENDANT PEOPLE MEDIA, INC.’S UNOPPOSED MOTION FOR EXTENSION OF
`TIME TO RESPOND AND MEMORANDUM IN SUPPORT THEREOF
`Defendant, People Media, Inc., respectfully moves the Court for an extension of time for
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`People Media to respond to Plaintiff’s Motion to Dismiss under Federal Rule of Civil Procedure
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`12(b)(6) and to Strike under Federal Rule of Civil Procedure 12(f) (Dkt. 33), which Plaintiff filed
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`on January 25, 2013.
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`1.
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`Plaintiff’s motion seeks relief under both Rule 12(b) and Rule 12(f).
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`2.
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`Pursuant to Local Rule 12.1, a party opposing a motion to dismiss under Rule
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`12(b) must file a response within 28 days. However, pursuant to Local Rule 7.2, a party
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`opposing a motion to strike under Rule 12(f) must file a response within 14 days.
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`3.
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`In the interest of efficiency, People Media prefers to address all of the issues
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`Plaintiff raised in its motion in a single response.
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`4.
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`People Media therefore requests that the Court grant an extension of time to
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`respond to the portion of Plaintiff’s motion seeking relief under Rule 12(f) such that the deadline
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`for People Media’s combined response is February 25, 2013.
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`WHEREFORE, People Media respectfully requests that the Court grant this motion and
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`allow it up to and including February 25, 2013 in which to file a combined response to Plaintiff’s
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`DEFENDANT PEOPLE MEDIA, INC’S UNOPPOSED MOTION FOR EXTENSION
`OF TIME TO RESPOND AND MEMORANDUM IN SUPPORT THEREOF
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`PAGE 1
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`Case 2:12-cv-02833-JPM-tmp Document 36 Filed 02/11/13 Page 2 of 3 PageID 354
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`Motion to Dismiss Under Fed. R. Civ. P. 12(b)(6) and Motion to Strike Under Fed. R. Civ. P.
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`12(f).
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`Dated: February 11, 2013
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`Respectfully submitted,
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`By: /s/ Steven G. Schortgen
`Steven G. Schortgen, pro hac vice
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`Texas Bar No. 00794603
`steve.schortgen@klgates.com
`Jennifer Klein Ayers, pro hac vice
`Texas Bar No. 24069322
`jennifer.ayers@klgates.com
`K&L Gates LLP
`1717 Main Street, Suite 2800
`Dallas, TX 75201
`(214) 939-5500
`(214) 939-5849 Facsimile
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`Sanjay K. Murthy, pro hac vice
`Illinois Bar No. 6279314
`sanjay.murthy@klgates.com
`Christopher E. Hanba, pro hac vice
`Illinois Bar No. 6298424
`christopher.hanba@klgates.com
`K&L Gates LLP
`70 W. Madison Street
`Suite 3100
`Chicago, Illinois 60602-4207
`(312) 372-1121
`(312) 827-8000 Facsimile
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`Jonathan D. Rose (No. 20967)
`jrose@babc.com
`BRADLEY ARANT BOULT
`CUMMINGS LLP
`1600 Division Street, Suite 700
`Nashville, Tennessee 37203
`(615) 252-2308
`(615) 252-6308 Facsimile
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`ATTORNEYS FOR DEFENDANT
`PEOPLE MEDIA, INC.
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`DEFENDANT PEOPLE MEDIA, INC’S UNOPPOSED MOTION FOR EXTENSION
`OF TIME TO RESPOND AND MEMORANDUM IN SUPPORT THEREOF
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`PAGE 2
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`Case 2:12-cv-02833-JPM-tmp Document 36 Filed 02/11/13 Page 3 of 3 PageID 355
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`CERTIFICATE OF CONSULTATION
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`Pursuant to Local Rule 7.2(a)(1)(B), I certify that counsel for Defendant, Jon Rose,
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`discussed the relief requested in this Motion with counsel for Plaintiff, Adam Simpson, on
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`February 11, 2013. The consultation was successful, as Mr. Rose and Mr. Simpson were able to
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`reach an agreement on the issues presented in the Motion. Adam Simpson advised that the
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`Plaintiff consents to the relief sought in the Motion.
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`/s/ Steven G. Schortgen
`Steven G. Schortgen
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`CERTIFICATE OF SERVICE
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`The foregoing document was filed on the Court’s CM/ECF system automatically
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`effecting service on counsel of record for all other parties who have appeared in this action on
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`the date of such service.
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`/s/ Steven G. Schortgen
`Steven G. Schortgen
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`DEFENDANT PEOPLE MEDIA, INC’S UNOPPOSED MOTION FOR EXTENSION
`OF TIME TO RESPOND AND MEMORANDUM IN SUPPORT THEREOF
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`PAGE 3