Ward v. Cisco Systems, Inc. et al

Filing 123

Unopposed MOTION for Extension of Time to File Sur-Reply as to 101 MOTION to Compel Responses to Cisco System, Inc.'s First Request for Production and Brief in Support Thereof by John Ward, Jr. (Patton, Nicholas) Modified on 10/22/2009 to edit text (cap).

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Ward v. Cisco Systems, Inc. et al Doc. 123 Case 4:08-cv-04022-JLH Document 123 Filed 10/21/09 Page 1 of 2 IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF ARKANSAS TEXARKANA DIVISION JOHN WARD, JR. v. CISCO SYSTEMS, INC. C.A. NO. 08-4022 JURY TRIAL DEMANDED PLAINTIFF'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE A SUR-REPLY REGARD CISCO'S MOTION TO COMPEL RESPONSES TO CISCO'S FIRST REQUEST FOR PRODUCTION To the Honorable Court: Plaintiff John Ward, Jr. respectfully requests that the Court grant him an extension of time to file a sur-reply regarding Cisco's Motion to Compel Responses to Cisco's First Request for Production and would show unto the Court as follows: 1. On or about October 13, 2009, Defendant filed its Reply to Plaintiff's Response to Cisco's Motion to Compel Responses to Cisco's First Request for Production (DE #115). 2. On October 21, 2009, Plaintiff's counsel contacted opposing counsel and asked for additional time to respond to Defendant's Reply. 3. Defendant's counsel has agreed to Plaintiff's request allowing Plaintiff to file his Sur- Reply on or before October 27, 2009. Wherefore, Plaintiff requests it be granted to and including October 27, 2009 to file a Sur-Reply Regarding Cisco's Motion to Compel Responses to Cisco's First Request for Production Upon Which Relief May Be Granted. Dockets.Justia.com Case 4:08-cv-04022-JLH Document 123 Filed 10/21/09 Page 2 of 2 Respectfully Submitted, Nicholas H. Patton State Bar No. 63035 Patton, Tidwell & Schroeder, LLP 4605 Texas Boulevard Texarkana, Texas 75503 903.792.7080 / 903.792.8233 (Fax) Patricia L. Peden LAW OFFICE OF PATRICIA L. PEDEN 1316 67th Street Oakland, California 94612 Telephone: 510-268-8033 ATTORNEYS FOR PLAINTIFF CERTIFICATE OF SERVICE This is to certify that on this 21st day of October, 2009, a true and correct copy of the foregoing was served electronically upon: Richard E. Griffin Charles Babcock Crystal Parker Kurt Schwarz JACKSON WALKER, LLP 1401 McKinney Suite 1900 Houston, Texas 77010 Attorney for Defendant Cisco Systems, Inc. Nicholas H. Patton 2

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