Professional Documents
Culture Documents
Motion 2
Motion 2
JOHNNY BLASH, x
Appellant, :
Appellees. :
_____________________________________ x
move this Court for extension of time to file any petitions for rehearing or
rehearing en banc to November 23, 2021 in order to allow the parties to complete
1. This Court issued a decision in this matter on April 21, 2021, affirming in
part and reversing in part the decision and order of the District Court.
2. On May 4, 2021 Appellant and Appellees sought and obtained over the
phone extensions of time until June 2, 2021 to file any petition for rehearing or
rehearing en banc.
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3. On May 28, 2021, the parries filed a joint motion requesting a further
facilitate a mediation that was scheduled for August 17, 2021. The Court granted
that motion.
4. The parties subsequently filed a second joint motion seeking to extend the
time to file the aforesaid motions to November 1, 2021, for the same purpose,
Counsel for the parties are currently drafting a formal settlement agreement and
agreement has been signed by the parties, they will file a stipulation of dismissal
to the District Court and thus to avoid further burdening either this Court or the
7. In view of the foregoing, the parties respectfully request that the time for
them to file any petition for rehearing or rehearing en banc be extended to and
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this matter to file any petition for rehearing or rehearing en banc be extended to
_s/Robert N. Marx_______
Robert N. Marx
Georgia Bar No. 475280
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JOHNNY BLASH, x
Appellant, :
Appellees. :
_____________________________________ x
Rule 26.1-1, Appellant Johnny Blash, certifies, by and through his undersigned
counsel of record, that to his knowledge the following constitutes a complete list of
the trial judge, attorneys, persons, associations of persons, firms, partnerships, and
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Owen, Gleaton, Egan, Jones & Sweeney, LLP, Attorneys for Appellees
s/Robert N. Marx______
Robert N. Marx, Esq.
Georgia Bar Number 475280
Jean Simonoff Marx, Esq.
Georgia Bar No. 475276
Marx & Marx, LLC
1050 Crown Pointe Parkway
Suite 500
Atlanta, Georgia 30338
Telephone: (404) 261-9559
[email protected]
Attorneys for Appellant Johnny Blash
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CERTIFICATE OF SERVICE
I hereby certify that I electronically filed the foregoing with the Clerk of the Court
for the United States Court of Appeals for the Eleventh Circuit by using the
appellate CM/ECF system on June 29, 2020.
I certify that the following are registered CM/ECF users and that service will be
accomplished by the appellate CM/ECF system:
Atlanta, Georgia
June 29, 2020
s/Robert N. Marx
Robert N. Marx, Esq.
Georgia Bar No. 475280
Marx & Marx, LLC
1050 Crown Pointe Parkway
Suite 500
Atlanta, Georgia 30338
Telephone: (404) 261-9559
[email protected]
Attorneys for Appellant Johnny Blash
Page C-3 of 3