Kern et al v. USA Travel Services et al

BRIEF in support of CONSENT MOTION for extension of time to file response/reply re AM Resorts' Motion to Dismiss 132

W.D. Mich.August 23, 2016

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION BRACE KERN, et. al. Case No: 1:16-CV-8 Plaintiffs, v HON. ROBERT HOLMES BELL USA TRAVEL SERVICES, et. al. Defendants. PLAINTIFFS’ BRIEF IN SUPPORT OF THEIR CONSENT MOTION FOR AN EXTENSION OF TIME TO RESPOND TO DEFENDANT AM RESORTS’ MOTION TO DISMISS Plaintiffs moved, pursuant to Federal Rule of Civil Procedure 6(b) and Rule 7.1(c) of the Western District of Michigan Local Rules, for an Order granting an extension of time through September 2, 2016 for Plaintiffs to respond to Defendant AM Resorts’ Motion to Dismiss or Transfer (ECF No. 109). On May 6, 2016, Plaintiffs filed an Amended Complaint adding additional party defendants. In response thereto, Defendant AM Resorts filed a Motion to Dismiss on July 26, 2016. The additional time requested herein will not prejudice any party, and the request, as well as this motion, were not made for any improper purpose. Case 1:16-cv-00008-RHB-RSK ECF No. 133 filed 08/23/16 PageID.606 Page 1 of 2 Page 2 of 2 On August 23, 2016, pursuant to Rule 7.1 of the Western District of Michigan Local Rules, Plaintiffs’ counsel sought and obtained Defendant’s consent to the relief requested in this motion. (See the Certificate of Concurrence filed concurrently herewith). Respectfully submitted, BEK Law, PLC Date: August 23, 2016 By: _/s/ Brace Kern_________________ Brace Kern (P75695) Attorney for Plaintiffs 3434 Veterans Drive Traverse City, MI 49684 (231) 492-0277 kern@law-bek.com CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the above and foregoing was filed on this 23rd day of August, 2016, with the Clerk of Court via the Court’s CM/ECF system for electronic service on all counsel of record. _/s/ Brace Kern_______________ Case 1:16-cv-00008-RHB-RSK ECF No. 133 filed 08/23/16 PageID.607 Page 2 of 2