Luxpro Corporation v. Apple, Inc.

Filing 13

MOTION to Extend Time by Apple, Inc.. (Crass, Kevin)

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Luxpro Corporation v. Apple, Inc. Doc. 13 IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF ARKANSAS TEXARKANA DIVISION LUXPRO CORPORATION VS. NO. 4-08-CV-4092 HFB PLAINTIFF APPLE INC. f/k/a Apple Computer, Inc. DEFENDANT DEFENDANT'S MOTION FOR EXTENSION OF TIME COMES now the Defendant, Apple Inc. f/k/a Apple Computer, Inc., and for its Motion for Extension of Time, states: 1. Plaintiff has filed a First Amended Complaint. The current date for the Defendant to file responsive pleadings to the First Amended Complaint is November 12, 2008. Defendant requests until December 19, 2008, to file pleadings responsive to Plaintiff's First Amended Complaint. 2. 3. Counsel for Plaintiff has kindly agreed to Defendant's request. In addition, counsel for Plaintiff and Defendant have agreed upon the proposed schedule for Plaintiff to respond to Defendant's responsive pleadings. Therefore, the parties request that the Court enter an Order allowing the Plaintiff until January 26, 2009, for Plaintiff to respond to responsive pleadings filed by the Defendant. 4. Finally, the parties have agreed to propose that the Defendant have until February 6, 2009, for the Defendant to reply to Plaintiff's responses. WHEREFORE, the Defendant, Apple Inc., with the consent of the Plaintiff, respectfully requests the Court enter an Order allowing Defendant until December 19, 2008, to file responsive pleadings to Plaintiff's First Amended Complaint, that Plaintiff be allowed until C:\NrPortbl\FEC\TMANESS\682803_1.DOC 1 Dockets.Justia.com January 26, 2009, to respond to those pleadings, and that the Defendant then be allowed until February 6, 2009, to file Reply Briefs. Respectfully submitted, KEVIN A. CRASS (84029) FRIDAY, ELDREDGE & CLARK, LLP 400 West Capitol Avenue, Suite 2000 Little Rock, Arkansas 72201-3522 Telephone: (501) 376-2011 Crass@fec.net Attorneys for Defendant, Apple Inc. f/k/a Apple Computer, Inc. BY: /s/ Kevin A. Crass KEVIN A. CRASS CERTIFICATE OF SERVICE I, Kevin A. Crass, hereby certify that on November 10, 2008, the foregoing was electronically filed with the Clerk which shall send notification of such filing to the following: Richard A. Adams radams@pattonroberts.com,shicks@pattonroberts.com,mcosta@pattonroberts.com Phillip N. Cockrell pcockrell@pattonroberts.com,kharris@pattonroberts.com Corey Darnell McGaha cmcgaha@pattonroberts.com,ssrebalus@pattonroberts.com Nicholas H. Patton nickpatton@texarkanalaw.com,mlong@texarkanalaw.com Leisa B. Pearlman lpearlman@pattonroberts.com,pdesantis@pattonroberts.com Patricia L. Peden ppeden@pedenlawfirm.com C:\NrPortbl\FEC\TMANESS\682803_1.DOC 2 I, Kevin A. Crass, hereby certify that on November 10, 2008, the foregoing was electronically filed with the Clerk and that a copy of the document and Notice of Electronic Filing were mailed, via United States Postal Service, to the following: Jeremy Y. Hutchinson Patton Roberts PLLC 111 Center Street, Suite 1315 Little Rock, Arkansas 72201 Patrick J. Conroy Glenn E. Janik Shore Chan Bragalone LLP Bank of America Plaza 901 Main Street, Suite 3300 Dallas, Texas 75202 /s/ Kevin A. Crass KEVIN A. CRASS (84029) FRIDAY, ELDREDGE & CLARK, LLP 400 West Capitol Avenue, Suite 2000 Little Rock, Arkansas 72201-3522 Telephone: (501) 376-2011 Crass@fec.net Attorneys for Defendant, Apple Inc. f/k/a Apple Computer, Inc. C:\NrPortbl\FEC\TMANESS\682803_1.DOC 3