SANDLER v. CALCAGNI et al

Filing 9

Unopposed MOTION to Extend Time to File Answer re 1 Complaint,, by BOOKSURGE LLC.Responses due by 5/9/2007. (Attachments: # 1 Text of Proposed Order Proposed Order)(WRIGHT, STEVEN)

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SANDLER v. CALCAGNI et al Doc. 9 UNITED STATES DISTRICT COURT DISTRICT OF MAINE SHANA SANDLER, a resident of High Point, County of Guilford, State of North Carolina Plaintiff v. MIA CALCAGNI, a resident of Winthrop, County of Kennebec, State of Maine, EMET GABAR, JOHN DOE, and/or JANE DOE, Co-Authors, BOOKSURGE, LLC, a South Carolina corporation with a place of business in Greenville, County of Greenville, State of South Carolina ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 07-CV-00029-DBH ASSENTED-TO MOTION TO EXTEND TIME TO FILE ANSWER BY DEFENDANT BOOKSURGE, LLC Defendant Booksurge, LLC, by and through its attorneys Kirkpatrick & Lockhart Preston Gates Ellis LLP, hereby moves to extend the time to file its answer to May 1, 2007. Defendant Booksurge, LLC consulted with counsel for Plaintiff Shana Sandler, Bernard J. Kubetz of Eaton Peabody. Mr. Kubetz agreed to an extension to May 1, 2007, for Defendant Booksurge, LLC to file its answer, so that Booksurge may obtain local counsel. BOS-1074403 v1 Dockets.Justia.com A proposed order granting this Motion to Extend Time to File Answer is submitted herewith. BOOKSURGE, LLC By its attorney, /s/ Steven P. Wright Steven P. Wright (ME BBO# 009473) Kirkpatrick & Lockhart Preston Gates Ellis LLP State Street Financial Center One Lincoln Street Boston, MA 02111-2950 April 18, 2007 CERTIFICATE OF SERVICE I, Steven P. Wright, hereby certify that this document filed through the ECF system will be sent electronically to the registered participants as identified on the Notice of Electronic Filing (NEF), and paper copies will be sent to those indicated as non-registered participants on April 18, 2007. /s/ Steven P. Wright Steven P. Wright -2-