Ward v. Cisco Systems, Inc. et al

Filing 10

Unopposed MOTION for Extension of Time to File Response/Reply as to 4 MOTION to Dismiss for Improper Venue, or in the Alternative, Motion to Transfer Venue by John Ward, Jr. (Patton, Nicholas)

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Ward v. Cisco Systems, Inc. et al Doc. 10 IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF ARKANSAS TEXARKANA DIVISION JOHN WARD, JR. Plaintiff V. CISCO SYSTEMS, INC. and RICK FRENKEL Defendants. No. 08-4022 JURY TRIAL DEMANDED UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO MOTION TO DISMISS FOR IMPROPER VENUE, OR IN THE ALTERNATIVE MOTION TO TRANSFER VENUE Comes now John Ward, Jr., Plaintiff in the above styled and numbered cause, and for his Unopposed Motion for Extension of Time to Respond to Motion to Dismiss for Improper Venue, or in the Alternative, Motion to Transfer Venue would show as follows: 1. On April 8, 2008, Defendant Cisco Systems, Inc. ("Cisco") filed its Motion to Dismiss for Improper Venue or in the Alternative, Motion to Transfer Venue. (DE #4) Plaintiff's response to said motion is due April 21, 2008. 2. Plaintiff requests a three day extension of time in which to file its response to Defendant Cisco's Motion to Dismiss for Improper Venue or in the Alternative, Motion to Transfer Venue making its response due April 24, 2008. 3. Defendant Cisco is unopposed to Plaintiff's request for extension of time. WHEREFORE, Plaintiff requests its request for extension of time be granted. Dockets.Justia.com Respectfully Submitted, /s/ Nicholas H. Patton Nicholas H. Patton State Bar No. 63035 Patton, Tidwell & Schroeder, LLP 4605 Texas Boulevard Texarkana, Texas 75503 Tel: (903) 792-7080 Fax: (903) 792-8233 Email: nickpatton@texaskanlaw.com Patricia L. Peden LAW OFFICE OF PATRICIA L. PEDEN 610 16th Street, Suite 400 Oakland, California 94612 Telephone: 510-268-8033 ATTORNEYS FOR PLAINTIFF 2 CERTIFICATE OF SERVICE This is to certify that on this 21st day of April, 2008, a true and correct copy of the foregoing Unopposed Motion for Extension of Time to Respond to Motion to Dismiss for Improper Venue, or in the Alternative Motion to Transfer Venue was served electronically and/or via U.S. First Class Mail upon: Richard E. Griffin Charles Babcock Crystal Parker JACKSON WALKER, LLP 1401 McKinney Suite 1900 Houston, Texas 77010 Attorney for Defendant Cisco Systems, Inc. Michael D. Barnes Attorney for Defendant Richard Frenkel WRIGHT, LINDSEY & JENNINGS, LLP 200 W. Capitol Avenue Little Rock, Arkansas 72201 George L. McWilliams 406 Walnut P.O. Box 58 Texarkana, Texas 75504-0058 Attorney for Defendant Richard Frenkel /s/ Nicholas H. Patton Nicholas H. Patton 3

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