CoStar Realty Information, Inc. et al v. Mark Field, et al

MOTION for Extension of Time

D. Md.April 9, 2008

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND CoSTAR REALTY INFORMATION, INC., 2 Bethesda Metro Center, 10th Floor Bethesda, Maryland 20814, and CoSTAR GROUP, INC. 2 Bethesda Metro Center, 10th Floor Bethesda, Maryland 20814, Plaintiffs, v. MARK FIELD D/B/A ALLIANCE VALUATION GROUP 2858 Via Bellota San Clemente, CA 92673, LAWSON VALUATION GROUP, INC. 8895 N. Military Trail, Suite 304E Palm Beach Gardens, FL 33410-6263, RUSS A. GRESSETT 5625 FM 1960 West, Suite 509 Houston, TX 77069 GERALD A. TEEL COMPANY, INC. 974 Campbell Rd., Suite 204 Houston, TX 77024-2813, PATHFINDER MORTGAGE COMPANY 23172 Plaza Pointe Dr., Suite 285 Laguna Hills, CA 92653, JOHN DOES 1-4 Addresses Currently Unknown, Defendants. _________________________________________/ Case No.: 8:08-CV-00663-AW DEFENDANT’S, LAWSON VALUATION GROUP, INC., UNOPPOSED MOTION FOR ENLARGEMENT OF TIME PMB 351841.1 CoStar Realty Information, Inc. et al v. Mark Field, et al Doc. 12 Dockets.Justia.com CoStar Realty Information, Inc. and CoStar Group, Inc. v. Mark Field, et al. Case No.: 8:08-CV-00663-AW Unopposed Motion for Enlargement of Time Defendant, Lawson Valuation Group, Inc. (“Lawson”), by and through its undersigned counsel, and pursuant to Fed.R.Civ.P. 6(b) and Local Rule 105(9), hereby files this instant Unopposed Motion for Enlargement of Time, and in support thereof, states as follows: 1. On or about March 13, 2008, Plaintiff commenced this action against, amongst others, Lawson. 2. Lawson was served with the Complaint on or about March 17, 2008. As such, Lawson’s response to the Complaint was due April 7, 2008. 3. On or about April 3, 2008, Plaintiff served an Amended Complaint adding a Defendant to this action. 4. Lawson’s response to the Amended Complaint is due April 14, 2008. 5. Lawson has just retained the undersigned counsel to represent it in this matter. 6. As a result of the complexity of the claims asserted in Plaintiff’s Amended Complaint, Lawson requests an additional eighteen (18) days to file its response to the Amended Complaint. 7. Plaintiff will not be prejudiced by the relief sought herein. Conversely, if the relief sought herein is not granted, Lawson will be substantially prejudiced in that they and their counsel will be unable to adequately prepare a response to the Amended Complaint. 8. Lawson has not previously sought an extension of time from this Court and the instant request is made in good faith and not for the purpose of delay. 9. On April 8, 2008, Simeon D. Brier of the undersigned law firm conferred with Plaintiff’s counsel regarding the relief sought herein. Plaintiff’s counsel agreed to an extension through and including May 2, 2008. PMB 351841.1 2 CoStar Realty Information, Inc. and CoStar Group, Inc. v. Mark Field, et al. Case No.: 8:08-CV-00663-AW Unopposed Motion for Enlargement of Time 10. Lawson’s proposed order is attached hereto as Exhibit A. WHEREFORE, Defendant, Lawson respectfully requests that this Court enter an Order granting it an additional eighteen (18) days to file its response to the above referenced Amended Complaint, and awarding Lawson such further relief as is necessary, just and proper. Respectfully submitted, EDWARDS ANGELL PALMER & DODGE LLP By: /s/ James E. Armstrong, IV James E. Armstrong, IV U.S.D.C. of Maryland Bar No.: 14592 1875 Eye Street, NW Washington, DC 20006 Telephone: (202) 478-7370 Facsimile: (202) 478-7380 Gary A. Woodfield Florida Bar No.: 563102 Simeon D. Brier Florida Bar No.: 525782 One North Clematis Street Suite 400 West Palm Beach, FL 33401 Telephone: (561) 833-7700 Facsimile: (561) 655-8719 PMB 351841.1 3 CoStar Realty Information, Inc. and CoStar Group, Inc. v. Mark Field, et al. Case No.: 8:08-CV-00663-AW Unopposed Motion for Enlargement of Time CERTIFICATE OF SERVICE I hereby certify that on April 9, 2008, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record or pro se parties identified on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing. /s/ James E. Armstrong, IV James E. Armstrong, IV PMB 351841.1 4 CoStar Realty Information, Inc. and CoStar Group, Inc. v. Mark Field, et al. Case No.: 8:08-CV-00663-AW Unopposed Motion for Enlargement of Time SERVICE LIST CoStar Realty Information, Inc., et al. v. Mar Field d/b/a Alliance Valuation Group, et al. Case No.: 8:08-CV-00663-AW United States District Court, District of Maryland (GreenBelt Division) Shari Ross Lahlou Bar No. 16570 E-mail: slahlou@crowell.com Sanya Sarich E-mail: ssarich@crowell.com Crowell & Moring LLP 1001 Pennsylvania Avenue, N.W. Washington, D.C. 20004 Telephone: (202) 624-2500 Facsimile: (202) 624-2500 Attorneys for Plaintiffs CoStar Realty Information, Inc. and CoStar Group, Inc. PMB 351841.1 5