United States of America v. Impulse Media Group Inc Doc.

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Case 2:05-cv-01285-RSL Document 34 Filed 10/16/2006 Page 1 of 2

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5 UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
6 AT SEATTLE
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UNITED STATES OF AMERICA,
8 No. CV05-1285L
Plaintiff,
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v. JOINT MOTION FOR LEAVE
10 TO EXTEND PRETRIAL
IMPULSE MEDIA GROUP, INC., ORDER DEADLINES
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a Washington corporation,
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Defendant. NOTE ON MOTION CALENDAR:
13 October 16, 2006
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Plaintiff United States of America and Defendant Impulse Media Group, Inc., by and
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through their undersigned counsel, hereby file this Joint Motion for Leave to Extend Pretrial
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Order Deadlines. The scheduling order entered by the Court (Docket # 7) requires the parties to
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mediate the case pursuant to CR 39.1(c)(3) by November 4, 2006. The scheduling order also
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requires the parties to submit an agreed pretrial order by November 22, 2006, and trial briefs,
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proposed voir dire questions, proposed jury instructions, and trial exhibits by November 29,
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2006.
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The parties have fully briefed Cross-Motions for Summary Judgment in this case.
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Consequently, Plaintiff and Defendant seek to extend the mediation deadline from November 4,
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2006, to thirty days after the Court has ruled on the pending Cross-Motions for Summary
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Judgment. The parties also request that the remaining deadlines set forth in the scheduling order
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be deferred until after the Court rules on the pending Cross-Motions for Summary Judgment and
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28 JOINT MOTION FOR LEAVE TO Department of Justice
EXTEND PRETRIAL ORDER DEADLINES P.O. Box 386
CV05-1285L Washington, DC 20044
-1- (202) 353-1991

Dockets.Justia.com
 Case 2:05-cv-01285-RSL Document 34 Filed 10/16/2006 Page 2 of 2

1 that the parties be given forty-five days after such ruling to jointly propose new deadlines for
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Dated: October 16, 2006
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CarpeLaw PLLC Lauren E. Hash
6 s/ Robert S. Apgood s/ Lauren E. Hash
Pro Hac Vice Trial Attorney
7 2400 NW 80th Street #130 Department of Justice
Seattle, WA 98117-4449 Office of Consumer Litigation
8 Telephone: (206) 624-2379 P.O. Box 386
Facsimile: (206) 784-6305 Washington, D.C. 20044
9 E-mail: rob@carpelaw.com Tel: (202) 353-1991
Fax: (202) 514-8742
10 lauren.hash@usdoj.gov
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28 JOINT MOTION FOR LEAVE TO Department of Justice
EXTEND PRETRIAL ORDER DEADLINES P.O. Box 386
CV05-1285L Washington, DC 20044
-2- (202) 353-1991