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

Filing 22

MOTION for Extension of Time to File Answer by Jabez Networks, Inc.. (Attachments: # 1 Text of Proposed Order)(Geiszler, Steven)

Beneficial Innovations, Inc. v. Blockdot, Inc. et al Doc. 22 Case 2:07-cv-00263-TJW-CE Document 22 Filed 07/20/2007 Page 1 of 3 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION BENEFICIAL INNOVATIONS, INC., Plaintiff, 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., Defendant. JABEZ NETWORKS, INC.'S UNOPPOSED MOTION FOR EXTENSION OF TIME IN WHICH TO ANSWER, MOVE, OR OTHERWISE RESPOND TO PLAINTIFF'S AMENDED COMPLAINT Defendant Jabez Networks, Inc. ("Jabez"), 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 ("Beneficial") Amended Complaint and would respectfully show the Court as follows: Jabez has requested and Beneficial has agreed to an extension of Jabez's time to respond in any manner whatsoever including answer, motion or other pleading of any type to Beneficial's Amended Complaint. Specifically, Jabez requests, and Beneficial does not oppose, an extension of time up to and including September 4, 2007. A proposed Order granting this unopposed motion is attached for the Court's convenience. CIVIL ACTION NO. 2:07-CV-263 (TJW/CE) Jury Trial Demand 100266585_1.DOC Dockets.Justia.com Case 2:07-cv-00263-TJW-CE Document 22 Filed 07/20/2007 Page 2 of 3 DATE: July 20, 2007 Respectfully submitted, GIBSON, DUNN & CRUTCHER LLP By: /s/ Mark N. Reiter MARK N. REITER Texas Bar No. 16759900 MReiter@gibsondunn.com STEVEN M. GEISZLER Texas Bar No. 24032227 SGeiszler@gibsondunn.com 2100 McKinney Avenue, Suite 1100 Dallas, Texas 75201 Telephone: (214) 698-3100 Facsimile: (214) 571-2900 ATTORNEYS FOR DEFENDANT JABEZ NETWORKS, INC. 100266585_1.DOC 2 Case 2:07-cv-00263-TJW-CE Document 22 Filed 07/20/2007 Page 3 of 3 CERTIFICATE OF CONFERENCE I certify that counsel for Jabez Networks, Inc. conferred with counsel for Beneficial Innovations, Inc. on July 19, 2007 regarding the subject matter of the foregoing motion. The motion is unopposed. /s/ Steven M. Geiszler _______________________ Steven M. Geiszler CERTIFICATE OF SERVICE I certify that the foregoing document was filed electronically on July 20, 2007 pursuant to Local Rule CV-5(a) and has been served on all counsel who have consented to electronic service. Any other counsel of record will be served by first class U.S. mail on this same date. /s/ Steven M. Geiszler _______________________ Steven M. Geiszler 100266585_1.DOC 3