The [eager] Beaver’s Lesson – Joint Motion filed in Renfroe v Rigsby

Then a scream, shrill and high, rent the shuddering sky,
And they knew that some danger was near:
The Beaver turned pale to the tip of its tail,
And even the Butcher felt queer.

Judge Acker’s latest order must have also called to mind the sound of … a pencil that squeaks on a slate – particularly the final point he directed toward the Renfroes – but such is surely expected as an [eager] Beaver’s Lesson in the Hunting of the Snark.

It is obvious at this juncture that plaintiff is unprepared to prove, and apparently does not claim, compensatory damages of the kind this court erroneously thought it was claiming. Plaintiff should not waste its time, or that of this court, undertaking to prove the amount of, or the reasonableness of, the attorneys’ fees it incurred in prosecuting this case.

“‘Tis the note of the Jubjub! Keep count, I entreat;
You will find I have told it you twice…

The Beaver had counted with scrupulous care,
Attending to every word:
But it fairly lost heart, and outgrabe in despair,
When the third repetition occurred.

It felt that, in spite of all possible pains,
It had somehow contrived to lose count,
And the only thing now was to rack its poor brains
By reckoning up the amount.

According to the Joint Motion for Extension of Time filed today in the case, a reckoning is exactly what’s taking place.

Plaintiff E. A. Renfroe & Company, Inc. and Defendants Cori Rigsby and Kerri Rigsby are negotiating a settlement that would resolve all the remaining issues in this case. Because of these on-going settlement negotiations, the parties jointly request that this Court extend the deadlines for briefing set out in the Order dated January 28, 2009… and the Memorandum Opinion and Order dated February 9,2009.

“The thing can be done,” said the Butcher, “I think.
The thing must be done, I am sure…

The Beaver brought paper,portfolio, pens,
And ink in unfailing supplies:
While strange creepy creatures came out of their dens,
And watched them with wondering eyes.

So engrossed was the Butcher, he heeded them not,
As he wrote with a pen in each hand,
And explained all the while in a popular style
Which the Beaver could well understand.

The parties seek to extend the deadlines stated in these two orders by two weeks to allow the parties to work out the details of settlement. If the parties do reach a settlement agreement, they will promptly notify this Court to seek abatement of all remaining deadlines.

ACCORDINGLY. the parties jointly and respectfully request that this Court amend its orders…to extend each deadline listed by fourteen calendar days.

“Taking Three as the subject to reason about–
A convenient number to state–
We add Seven, and Ten, and then multiply out
By One Thousand diminished by Eight.

“The result we proceed to divide, as you see,
By Nine Hundred and Ninety Two:
Then subtract Seventeen, and the answer must be
Exactly and perfectly true.

“The method employed I would gladly explain,
While I have it so clear in my head,
If I had but the time and you had but the brain–
But much yet remains to be said.

Lacking both the time and the brain to understand what issues remain, I can only offer:

...when quarrels arose–as one frequently finds
Quarrels will, spite of every endeavor–
The song of the Jubjub recurred to their minds…

With all the Jubjub singing here this week, 14 days isn’t too much to ask.



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