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Case No.: 48-2007-CA-014233-O Page 1 of 4 Agreed Mtn to Continue CMC
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT,
IN AND FOR ORANGE COUNTY, FLORIDA
WRIGHT ENTERTAINMENT
GROUP, LLC and WRIGHT
ENTERTAINMENT GROUP, INC.,
Plaintiffs,
vs.
BRITNEY SPEARS and BRITNEY
TOURING, INC.,
Defendants. /
CASE NO: 48-2007-CA-014233-O
DIVISION: 32
AGREED MOTION FOR CONTINUANCE OF
CASE MANAGEMENT CONFERENCE
COME NOW the Plaintiffs, WRIGHT ENTERTAINMENT GROUP, LLC
and WRIGHT ENTERTAINMENT GROUP, INC., by and through their
undersigned counsel, and file this Motion for Continuance of Case Management
Conference currently scheduled for March 10, 2008, and in support thereof states
as follows:
1. This Court entered its Notice of Hearing and Order on Case
Management Conference scheduling the Case Management Conference in this
matter on March 10, 2008 at 3:45 p.m. This notice was served on the Defendant,
BRITNEY SPEARS, personally on November 1, 2007.
2. On December 18, 2007, this Court issued a Clerk’s Default against the
Defendants, BRITNEY SPEARS and BRITNEY TOURING, INC.
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Case No.: 48-2007-CA-014233-O Page 2 of 4 Agreed Mtn to Continue CMC
3. On February 14, 2008, this Court entered Final Judgments by Default
against the Defendants.
4. On February 14, 2008, this Court also issued an Order compelling
Defendants to respond to Plaintiffs’ discovery requests previously served upon the
Defendant, BRITNEY SPEARS, on November 1, 2007 and Defendant, BRITNEY
TOURING, INC., on November 9, 2007, in aid of execution.
5. On February 14, 2008, Plaintiffs filed Notices of Production from
Non-Parties to conduct discovery in aid of execution.
6. On February 22, 2008, Plaintiffs’ counsel advised the counsel for the
Conservator for the Estate of Britney Spears, Jerryll Cohen, Esquire, of the Case
Management Conference scheduled for March 10, 2008 and enclosing copies of
the Clerk’s Defaults, Final Judgments by Default, Order compelling discovery and
the Plaintiffs’ discovery requests.
7. On March 3, 2008, counsel for the Conservator for the Estate of
Britney Spears, Jerryll Cohen, Esquire, contacted the Plaintiffs’ counsel with
regard to the Defendants’ intention to secure local counsel in this matter and to
request copies of pleadings.
8. On March 4, 2008, Plaintiffs’ counsel electronically forwarded to Ms.
Cohen, a copy of the Complaint and exhibits attendant thereto, a copy of the
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Case No.: 48-2007-CA-014233-O Page 3 of 4 Agreed Mtn to Continue CMC
Notice of Production from Non-Parties, and the Notice Regarding Non-Destruction
of Electronic Data or Computer Files.
9. On March 6, 2008, pursuant to BCP 5.3, Plaintiffs’ counsel and
counsel for the Conservator for the Estate of Britney Spears have conferred and
agreed to file this Agreed Motion for Continuance of the Case Management
Conference to occur within the next 30 days or upon order of this Court.
10. Given the recent contact by Defendants’ Conservator’s counsel, the
Plaintiffs request additional time for the Defendants to secure local counsel in this
matter prior to the entry of a Case Management Order.
WHEREFORE, Plaintiffs’ counsel requests that this Honorable Court grant
a continuance of the Case Management scheduled for March 10, 2008, at 3:45 p.m.
for at least thirty (30) days or at such other time as this Court deems just.
Respectfully submitted this 6th day of March, 2008.
/s/ Clay M. Townsend
CLAY M. TOWNSEND, ESQ.
FBN: 363375
Morgan & Morgan, P.A.
20 N. Orange Ave., 16th Floor
P.O. Box 4979
Orlando, FL 32802-4979
Telephone: (407) 420-1414
Facsimile: (407) 425-8171
Attorneys for Plaintiffs
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished, by facsimile and U.S. Mail postage paid, this 6th day of March, 2008,
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Case No.: 48-2007-CA-014233-O Page 4 of 4 Agreed Mtn to Continue CMC
to: James P. Spears, c/o Jeryll S. Cohen, Esq., Luce, Forward, Hamilton & Scripps,
LLP, 601 S. Figueroa Street, Suite 3900, Los Angeles, CA 90017; Andrew Wallet,
Esq., Hinojosa & Wallet, 2215 Colby Avenue, Los Angeles, CA 90064; Samuel
D. Ingham, III, Esq., 9440 Santa Monica Blvd., Suite 510, Beverly Hills, CA
90210; and Britney Touring, Inc., c/o Corporation Service Company, 1201 Hays
Street, Tallahassee, FL 32301-2525.
/s/ Clay M. Townsend
CLAY M. TOWNSEND, ESQ.
FBN: 363375
Morgan & Morgan, P.A.
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