Motorola Mobility, Inc. v. Microsoft Corporation

Filing 17

Unopposed MOTION for Extension of Time to File Answer RE: Complaints re #1 Complaint, Defendant Microsoft Corporation's Unopposed Motion for Extension of Time to File Response to Complaint by Microsoft Corporation. (Attachments: #1 Text of Proposed Order)(Miner, Curtis)

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Motorola Mobility, Inc. v. Microsoft Corporation Doc. 17 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 1:10-cv-24063-MORENO ) ) ) ) ) ) ) ) ) ) ) MOTOROLA MOBILITY, INC., Plaintiff, vs. MICROSOFT CORPORATION, Defendant. DEFENDANT MICROSOFT CORPORATION'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO COMPLAINT Defendant Microsoft Corporation ("Microsoft"), by and through its undersigned counsel, hereby moves for a two-week extension of time in which to file its response to Plaintiff Motorola Mobility, Inc.'s Complaint [Doc. 1]. Plaintiff's counsel has advised agreed to the requested extension of time. In support of this request, Defendant Microsoft states as follows: 1. Plaintiff Motorola Mobility, Inc filed its Complaint [Doc. 1] on November 10, 2010. Defendant Microsoft was served with the Complaint on November 18. 2. Defendant Microsoft's response to the Complaint would ordinarily be due by December 9, 2010. 3. Because of the complexity of this matter, and the consequent need for additional time to answer or otherwise move the Court for relief, Defendant Microsoft is requesting the relatively brief extension of two weeks in order to file its response to the Complaint by December 23, 2010. 4. Counsel for Defendant Microsoft has conferred with counsel for Plaintiff, and Plaintiff's counsel has agreed to the requested extension. WHEREFORE, Defendant Microsoft respectfully requests that the Court enter the accompanying proposed Order granting a two-week extension (until December 23, 2010) in which to respond to the Complaint. Respectfully submitted, COLSON HICKS EIDSON Roberto Martinez, Esq. Curtis Miner, Esq. 255 Alhambra Circle, Penthouse Coral Gables, Florida 33134 Tel. (305) 476-7400 Fax. (305) 476-7444 By: ___s/ Curtis B. Miner Curtis B. Miner (Fla. Bar No. 885681) E-mail: Of Counsel: David T. Pritikin Richard A. Cederoth Douglas I. Lewis John W. McBride SIDLEY AUSTIN LLP One South Dearborn Chicago, IL 60603 Tel: (312) 853-7000 Brian R. Nester Kevin C. Wheeler SIDLEY AUSTIN LLP 1501 K Street NW Washington, DC 20005 Tel: (202) 736-8000 2 CERTIFICATE OF SERVICE I hereby certify that on December 6, 2010, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record or pro se parties identified on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing. _s/ Curtis B. Miner___________ Curtis B. Miner, Esq. SERVICE LIST Motorola Mobility, Inc. v. Microsoft Corp., Case No. 1:10-cv-24063-Moreno Edward M. Mullins, Esq. Hal M. Lucas ASTIGARRAGA DAVIS 701 Brickell Avenue, 16th Floor Miami, FL 33131 Tel.: (305) 372-8282 Steven Pepe Jesse J. Jenner ROPES & GRAY LLP 1211 Avenue of the Americas New York, NY 10036-8704 Tel: (212) 596-9046 Norman H. Beamer Mark D. Rowland Gabrielle E. Higgins ROPES & GRAY LLP 1900 University Avenue, 6th Floor East Palo Alto, CA 94303-2284 Tel: (650) 617-4030 Counsel for Plaintiff Motorola Mobility, Inc. 3

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