Beneficial Innovations, Inc. v. Blockdot, Inc. et al

Filing 19

MOTION for Extension of Time to File Answer re 7 Amended Complaint [Unopposed] by The Washington Post Company. (Attachments: # 1 Text of Proposed Order)(Jones, Michael)

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Beneficial Innovations, Inc. v. Blockdot, Inc. et al Doc. 19 Case 2:07-cv-00263-TJW-CE Document 19 Filed 07/17/2007 Page 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION BENEFICIAL INNOVATIONS, INC. v. BLOCKDOT, INC., CAREERBUILDER, LLC, CNET NETWORKS, INC., DIGG, INC., EBAUM'S WORLD, INC., JABEZ NETWORKS, INC., THE NEW YORK TIMES CO., THE WASHINGTON POST CO., THE WEATHER CHANNEL INTERACTIVE, INC. CASE NO. 2:07-cv- 263[TJW-CE] Jury Trial Demand DEFENDANT THE WASHINGTON POST CO.'S UNOPPOSED MOTION FOR EXTENSION OF TIME IN WHICH TO ANSWER, MOVE, OR OTHERWISE RESPOND TO PLAINTIFF'S AMENDED COMPLAINT Defendant THE WASHINGTON POST CO., without waiving any defenses or any matters that might be presented pursuant to FEDERAL RULE OF CIVIL PROCEDURE 12(b) or any other rule or law, files this unopposed motion for extension of time in which to answer, move, or otherwise respond to Plaintiff BENEFICIAL INNOVATIONS, INC.'S Amended Complaint and would respectfully show the Court as follows: THE WASHINGTON POST CO. has requested and Plaintiff has agreed to an extension of THE WASHINGTON POST CO.'S time to respond in any manner whatsoever including answer, motion or other pleading of any type to Plaintiff's Amended Complaint. Specifically, THE WASHINGTON POST CO. requests, and BENEFICIAL INNOVATIONS, INC. does not oppose, an additional extension of time up to and including September 4, 2007. A proposed Order granting this unopposed motion is attached for the Court's convenience. {A07\7820\0001\W0330953.1 } Dockets.Justia.com Case 2:07-cv-00263-TJW-CE Document 19 Filed 07/17/2007 Page 2 of 2 Dated: July 17, 2007 Respectfully submitted, By: /s/ Michael E. Jones Michael E. Jones State Bar No. 10929400 POTTER MINTON A Professional Corporation 110 N. College, Suite 500 (75702) P. O. Box 359 Tyler, Texas 75710 (903) 597 8311 (903) 593 0846 (Facsimile) mikejones@potterminton.com ATTORNEYS FOR DEFENDANT THE WASHINGTON POST CO. CERTIFICATE OF SERVICE I hereby certify that all counsel of record who have consented to electronic service are being served with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3) on this the 17th day of July, 2007. Any other counsel of record will be served by first class U.S. mail on this same date. /s/ Michael E. Jones Michael E. Jones {A07\7820\0001\W0330953.1 }