Case: 1:11-cv-00103-GHD-DAS Doc #: 324 Filed: 11/12/13 1 of 4 PageID #: 6210
IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF MISSISSIPPI EASTERN DIVISION KMART CORPORATION VS.
PLAINTIFF CIVIL ACTION NO.: 1:11-CV-103-GHD-JAD
THE KROGER CO., E&A SOUTHEAST LIMITED PARTNERSHIP; FULTON IMPROVEMENTS, LLC; KANSAS CITY SOUTHERN RAILWAY COMPANY; CITY OF CORINTH; THE UNITED STATES OF AMERICA; JOHN DOE; AND ABC CORPORATION
DEFENDANTS
MOTION TO WITHDRAW MOTION FOR EXTENSION OF TIME TO FILE REPLY IN SUPPORT OF MOTION TO EXCLUDE TESTIMONY OF JOHN R. KREWSON COMES NOW, Defendant, Fulton Improvements, LLC, by and through its attorneys, Jacks Luciano, P.A., and files this its Motion to Withdraw Motion for Extension of Time to File its Reply in Support of Motion in Limine to Exclude Expert Testimony of John R. Krewson, and in support thereof would state unto the Court as follows, to-wit: 1.
On November 7, 2013, Fulton filed a Motion for Extension of Time to File its
Reply in Support of Motion to Exclude the Testimony of John R. Krewson [Doc 313]. Fulton asked to have until November 18, 2013 to file its Reply in Support of its Motion to Exclude the Testimony of John R. Krewson. However, at the time the request for additional time was filed, Plaintiff Kmart had not actually filed its Response with this Court. Instead, Kmart had only filed a motion for leave to file its response, which this Court granted on November 4, 2013. WHEREFORE PREMISES CONSIDERED, the Defendant respectfully requests that this Honorable Court enter an order withdrawing its Motion for Additional Time to File a Reply by a November 18, 2013 deadline.
Case: 1:11-cv-00103-GHD-DAS Doc #: 324 Filed: 11/12/13 2 of 4 PageID #: 6211
THIS, the 12th day of November, 2013. RESPECTFULLY SUBMITTED, JACKS LUCIANO, P.A. Attorneys for Defendant By: /s/ Jamie F. Jacks JAMIE FERGUSON JACKS, MSB No. 101881 GERALD H. JACKS, MSB No. 3232 Post Office Box 1209 Cleveland, Mississippi 38732 Telephone: 662-843-6171
Case: 1:11-cv-00103-GHD-DAS Doc #: 324 Filed: 11/12/13 3 of 4 PageID #: 6212
CERTIFICATE OF SERVICE I, Jamie F. Jacks, Attorney for Defendant, Fulton Improvements, LLC, do hereby certify that I have this date ECF filed the above and foregoing MOTION TO WITHDRAW MOTION FOR EXTENSION OF TIME TO FILE REPLY IN SUPPORT OF MOTION TO EXCLUDE TESTIMONY OR JOHN R. KREWSON to: Ryan O. Luminais James M. Garner John T. Balhoff, II Sher Garner Cahill Richter Klein & Hilbert, LLC 909 Poydras Street, 28th Floor New Orleans, LA 70112 David A. Norris Edley H. Jones, III Stephen Friedrich Schelver McGlinchey Stafford, PLLC P.O. Drawer 22949 Jackson, MS 39225-2949 Mary Clift Abdalla Forman, Perry, Watkins, Krutz & Tardy, PLLC 200 S. Lamar Street, Suite 100 Jackson, MS 39201 Walter G. Watkins, Jr. Walter Garner Watkins, III Forman, Perry, Watkins, Krutz & Tardy, PLLC P. O. Box 22608 Jackson, MS 39225-2608 Charles E. Ross Linda F. Cooper Wise Carter Child & Caraway P.O. Box 651 Jackson, MS 39205
Case: 1:11-cv-00103-GHD-DAS Doc #: 324 Filed: 11/12/13 4 of 4 PageID #: 6213
Shelly Mott Bass Terry Dwayne Little Wilton V. Byars, III Daniel Coker Horton & Bell, P.A. P.O. Box 1396 Oxford, MS 38655-1396 John Evans Gough, Jr. U. S. Attorney’s Office 900 Jefferson Avenue Oxford, MS 38655-3608 THIS, the 12TH day of November, 2013. /s/ Jamie F. Jacks JAMIE F. JACKS