Vulcan Golf, LLC v. Google Inc. et al

Filing 26

MOTION by Defendant Sedo LLC for extension of time to Answer or Otherwise Respond (Attachments: # 1 Exhibit A - Proposed Order)(Martin, Misty)

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Vulcan Golf, LLC v. Google Inc. et al Doc. 26 Case 1:07-cv-03371 Document 26 Filed 07/23/2007 Page 1 of 2 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION ) ) ) ) ) Vs. ) ) GOOGLE INC., OVERSEE NET, ) SEDO, LLC, [misnamed] DOTSTER, INC., AKA ) INTERNET REIT, INC., d/b/a IREIT, INC., ) And JOHN DOES I-X ) Defendants. ) VULCAN GOLF, LLC, Individually and on behalf of all Others Similarly Situated, Lead Plaintiff, No. 07 CV 3371 Judge Kocoras Magistrate Judge Brown MOTION FOR EXTENSION OF TIME FOR DEFENDANT SEDO.COM, LLC TO ANSWER OR OTHERWISE PLEAD Defendant, LLC (misnamed Sedo, LLC), by and through its attorneys, Segal McCambridge Singer & Mahoney, respectfully moves this Court to extend until September 15, 2007 the date by which must answer or otherwise plead to the Class Action Complaint ("Complaint"). In support of this motion, Defendant states as follows: 1. On June 15, 2007, Plaintiff filed the Complaint in this matter. was served with a copy of the Summons and Complaint on June 27, 2007. Accordingly,'s response pleading was due on July 19, 2007. 2. The Complaint is 121 pages in length, contains at least 638 paragraphs and asserts class action federal and state law claims alleging infringement and deceptive practices of registered marks, trade names, logos and other distinctive/valuable marks. 3. Given the extraordinary size of the Complaint and the nature of the claims raised therein, Defendant respectfully submits that it will need additional time to properly review and digest the Complaint in order to adequately prepare a responsive pleading. 814610-1 Case 1:07-cv-03371 Document 26 Filed 07/23/2007 Page 2 of 2 4. Plaintiff's counsel has been apprised of the basis of this motion and has acknowledged's need for an extension of time, but will only agree to an extension until August 17, 2007. Unfortunately, given the complexity and nature of Plaintiff's claims, will need additional time to respond to Plaintiff's complaint. 5. brings this motion in good faith and not for the purposes of undue delay. Further,, LLC cannot foresee any unfair prejudice that will suffer Plaintiff if it is granted an extension of time until September 15, 2007 to respond to Plaintiff's Complaint. 6. entitled action. 7. Attached herein as Exhibit A is a Proposed Order Extending Defendant's Time in No previous request for extension has been made by this Defendant in the above- Which to Answer or Otherwise Plead. WHEREFORE, for the foregoing reasons, Defendant, LLC, respectfully requests that the Court extend until September 15, 2007, the date by which it must answer or otherwise plead to the Class Action Complaint. Respectfully submitted, By: /s/Misty R. Martin_____________ One of, LLC's Attorneys Jeffrey Singer Misty R. Martin Segal McCambridge Singer & Mahoney 233 South Wacker Drive Sears Tower Suite 5500 Chicago, IL 60606 (312) 645-7800 (t) (312) 645-4463 (f) 814610-1

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