Page 1 of 3 – Defendant Spirit Airlines, Inc.’s Unopposed Motion 

for Extension of Deadline 

The Rosen Law Firm, P.C. 

1000 SW Broadway, Suite 1220 

Portland, Oregon 97205 

Phone: (503) 525-2525; Fax: (503) 525-2526 

Steven O. Rosen, OSB #785009 

Rosen@RosenLawFirm.com 

Elizabeth M. Ferrarini OSB #944859 

Ferrarini@RosenLawFirm.com 

The Rosen Law Firm, P.C. 

1000 SW Broadway, Suite 1220 

Portland, OR 97205 

Telephone: (503) 525-2525 

Facsimile: (503) 525-2526 

Attorneys for Defendant 

Spirit Airlines, Inc.

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

PORTLAND DIVISION 

TIMOTHY MEACHAM, 

 Plaintiff, 

v. 

SPIRIT AIRLINES INC. and; KERRIE 

CONRAD,

 Defendants. 

Case No. 3:15-cv-00338-SI 

DEFENDANT SPIRIT AIRLINES 

INC.’S UNOPPOSED MOTION 

FOR EXTENSION OF DEADLINE

CERTIFICATE OF COMPLIANCE WITH LR 7-1(a) 

 I hereby certify that defense counsel for Spirit Airlines, Inc. has conferred 

with counsel for the plaintiff in a good faith effort to resolve this matter. The 

parties agreed to the following request, and this motion is unopposed. 

Case 3:15-cv-00338-SI Document 2 Filed 02/25/15 Page 1 of 4
Page 2 of 3 – Defendant Spirit Airlines, Inc.’s Unopposed Motion 

for Extension of Deadline 

The Rosen Law Firm, P.C. 

1000 SW Broadway, Suite 1220 

Portland, Oregon 97205 

Phone: (503) 525-2525; Fax: (503) 525-2526 

MOTION 

 Pursuant to LR 16-3, defendant Spirit Airlines, Inc. moves the Court for an 

extension of time to Monday, March 23, 2015 to file its Answer or otherwise 

respond to the plaintiff’s Complaint. 

MEMORANDUM IN SUPPORT OF MOTION 

 Defendant Spirit Airlines, Inc. was served with the Summons and Complaint 

on January 30, 2015. On February 25, 2015 Spirit Airlines, Inc. removed this 

action from Oregon state court to the U.S. District Court for the District of Oregon. 

Rule 81(c)(2)(C) of the Federal Rules of Civil Procedure would require Spirit 

Airlines to file its Answer within 7 days of removal. However, Spirit Airlines 

requests additional time to investigate the claims and to draft its Answer. 

 Defense counsel for Spirit Airlines spoke with Mr. Ball, counsel for the 

plaintiff, on February 25, 2015 and requested additional time to prepare and file an 

Answer. Mr. Ball agreed with that request and defendant Spirit Airlines seeks 

court approval of the extension of time in accordance with LR 16-3 and 29-1. 

 It is the understanding of Spirit Airlines that its co-defendant, Kerrie Conrad, 

has not yet been served. It is not expected that this requested extension of time 

will cause any significant delay in the progression of the action, especially given 

the fact that one of the parties has not been served. 

Case 3:15-cv-00338-SI Document 2 Filed 02/25/15 Page 2 of 4
Page 3 of 3 – Defendant Spirit Airlines, Inc.’s Unopposed Motion 

for Extension of Deadline 

The Rosen Law Firm, P.C. 

1000 SW Broadway, Suite 1220 

Portland, Oregon 97205 

Phone: (503) 525-2525; Fax: (503) 525-2526 

 This motion is made in good faith and not for purposes of delay. Spirit 

Airlines respectfully requests that the Court grant its request for an extension of 

time. 

DATED this 25th of February, 2015. 

 s/ Steven O. Rosen 

 Steven O. Rosen, OSB # 785009 

Rosen@RosenLawFirm.com 

Of Attorneys for Defendant Spirit Airlines, Inc. 

Case 3:15-cv-00338-SI Document 2 Filed 02/25/15 Page 3 of 4
Page 1 - Certificate of Service The Rosen Law Firm, P.C. 

1000 SW Broadway, Suite 1220 

Portland, Oregon 97205 

Phone: (503) 525-2525; Fax: (503) 525-2526 

 

 

CERTIFICATE OF SERVICE 

 I hereby certify that I served a copy of the foregoing DEFENDANT 

SPIRIT AIRLINES INC.’S UNOPPOSED MOTION FOR EXTENSION OF 

DEADLINE by the following indicated method or methods: 

 by mailing full, true, and correct copies thereof in sealed, 

 first-class postage-prepaid envelopes, addressed to the 

 attorney(s) as shown below, the last-known address(es) of the 

attorney(s) and deposited with the United States Postal Service 

at Portland, Oregon on the date set forth below. 

 by causing full, true, and correct copies thereof to be 

hand-delivered via messenger to the attorney(s) at the last-known 

 address(es) listed below on the date set forth below. 

 Notice of this filing will be sent by e-mail to plaintiff’s counsel by operation 

 of the Court’s electronic filing system. Parties may access this filing 

 through the Court’s CM/ECF system. 

 

Mr. William Ball 

Attorney William Ball, LLC 

420 SW Washington, Suite 400 

Portland, OR 97204

Attorney for plaintiff Timothy Meacham 

 DATED this 25th day of February, 2015. 

 

 s/ Steven O. Rosen 

Steven O. Rosen, OSB #785009 

Case 3:15-cv-00338-SI Document 2 Filed 02/25/15 Page 4 of 4