The document is a motion filed by attorney Gary Brown requesting a 90-day extension to file an opening brief on behalf of appellants Heal the World Foundation and United Fleet. The appellants' previous attorney withdrew from the case on September 11, 2012 and the appellants had until October 9, 2012 to find new representation or face termination of their appeal. Attorney Brown entered his appearance on November 8, 2012 after the appellants conducted a diligent search for counsel. Brown requests additional time to review the extensive record in the case, which includes over 35 sealed documents, before drafting the opening brief.
The document is a motion filed by attorney Gary Brown requesting a 90-day extension to file an opening brief on behalf of appellants Heal the World Foundation and United Fleet. The appellants' previous attorney withdrew from the case on September 11, 2012 and the appellants had until October 9, 2012 to find new representation or face termination of their appeal. Attorney Brown entered his appearance on November 8, 2012 after the appellants conducted a diligent search for counsel. Brown requests additional time to review the extensive record in the case, which includes over 35 sealed documents, before drafting the opening brief.
The document is a motion filed by attorney Gary Brown requesting a 90-day extension to file an opening brief on behalf of appellants Heal the World Foundation and United Fleet. The appellants' previous attorney withdrew from the case on September 11, 2012 and the appellants had until October 9, 2012 to find new representation or face termination of their appeal. Attorney Brown entered his appearance on November 8, 2012 after the appellants conducted a diligent search for counsel. Brown requests additional time to review the extensive record in the case, which includes over 35 sealed documents, before drafting the opening brief.
Pasadena, CA 91105-1945 Telephone: (818) 293-0979 Facsimile: (818) 293-0760 email: [email protected] Attorney for Heal the World Foundation and United Fleet UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT John Branca, et al ) CA NO. 11-56926 ) Appellees/Plaintiffs, ) DC No. CV 09-07084-DMG (PLAx) ) v. ) APPELLANTS MOTION TO ) EXTEND TIME TO FILE Heal the World Foundation, et al, ) OPENING BRIEF ) Appellant/Defendants. ) ) Appellants Heal The World Foundation and United Fleet, through incoming undersigned counsel, hereby requests a 90-day extension of time to file their opening brief which was due November 8, 2012, for the reasons which follow. Because of the timing of this application opposing counsel has not yet been consulted. It is anticipated that a telephone call will be made on November 13, 2012, and the results immediately reported. I
On September 11, 2012, appellants attorney of record Jeremy D. Evelands
motion to withdraw as counsel on appeal was granted. [Docket Entry (DE) 23.] That order also directed appellants to enter an appearance of new counsel within 21 days or face termination of the appeal. [Id.] The due date for appellants opening brief(s) was reset to October 9, 2012. [Id.] Appellants conducted a diligent search for new counsel which was hampered by lack of funds to hire an attorney and the immense record of this matter, including some 35 sealed documents and other information that should have been offered in the underlying matter but wasnt. The search resulted in undersigned counsels appearance for appellants here on November 8, 2012, following setting up electronic access that date. [DE 24.] This application for time was initially prepared on November 8 with an intention to file it on November 9, 2012. That date counsel was engaged in a deposition that was scheduled for three hours and took all day thereby delaying his return to the office until after 5:30 p.m., so this application follows over the weekend. II Undersigned counsel has commenced to accumulate the extensive record, including a determination of how many of the 35 or so sealed documents have been unsealed thus far and how many still remain so and require motions to unseal. That effort will require some time before a draft of the opening brief can be 2
constructed. Counsel therefore requests this Court of Appeals grant an additional
90 days to file an opening brief. III For the reasons stated, appellants requests a 90 day extension from November 8, 2012 to file their opening brief . DATED: November 10, 2012 ______/s/__________ GARY S. BROWN Attorney for Appellants 3
Defendant Scott Nago's Counter-Motion for Summary Judgment; Memorandum of Law in Opposition to Plaintiff's Motions for Preliminary Injunction and Partial Summary Judgment and in Support of Defendant's Counter-Motion for Summary Judgment, Democratic Party of Hawaii v. Nago, No. CV13-00301 JMS/KSC (Sep. 16, 2013)
SECOND REPLY With SECOND SUPPLEMENT With REPLY To Response in RE NOM To RENEW Strunk V NYS Board of Elections Et Al. NYS SC Kings County Index No 6500-2011