MDG INTERNATIONAL, INC. v. AUSTRALIAN GOLD, INC.

Filing 21

MDG INTERNATIONAL, INC. v. AUSTRALIAN GOLD, INC.

Doc. 21

Case 1:07-cv-01096-SEB-TAB

Document 21

Filed 11/09/2007

Page 1 of 2

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION MDG INTERNATIONAL, INC., Plaintiff, v. AUSTRALIAN GOLD, INC., Defendant. ) ) ) ) ) ) ) ) )

Cause No. 1:07-cv-01096-SEB-TAB

NOTICE OF INITIAL EXTENSION OF TIME TO RESPOND TO DEFENDANT'S COUNTERCLAIM Pursuant to Local Rule 6.1, Plaintiff MDG International, Inc. ("MDG"), by counsel, hereby notifies the Court of its initial extension of time within which to respond to Defendant Australian Gold's Counterclaim and Demand for Jury Trial. In support of its notice, MDG states as follows: 1. 2. Australian Gold served its Answer and Counterclaim on October 17, 2007. MDG's response to Australian Gold's Counterclaim is due November 9,

2007. This time expires today. 3. MDG requires additional time to prepare and file a response to Australian

Gold's Counterclaim. 4. Counsel for MDG has conferred with counsel for Australian Gold to

request an initial 30-day extension of time to respond to Australian Gold's Counterclaim. Counsel for Australian Gold has no objection to this request. 5. After a 30-day extension, MDG's new deadline to file a response to

Australian Gold's Counterclaim is Monday, December 10, 2007. 6. MDG is not seeking this enlargement of time for the purpose of delay.

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Case 1:07-cv-01096-SEB-TAB

Document 21

Filed 11/09/2007

Page 2 of 2

THEREFORE, pursuant to Local Rule 6.1, MDG's response to Australian Gold's Counterclaim and Demand for Jury trial is now due on or before Monday, December 10, 2007. Respectfully submitted: /s/ Elizabeth A. Schuerman________ Edward O. DeLaney (#4466-49) Kathleen A. DeLaney (#18604-49) Elizabeth A. Schuerman (#26577-49) Attorneys for MDG International, Inc. CERTIFICATE OF SERVICE The undersigned hereby certifies that a copy of the foregoing was filed electronically on November 9, 2007. Notice of this filing will be sent to the following parties by operation of the Courts electronic filing system. Parties may access this filing through the Court's system: Thomas F. O'Gara [e-mail] Richard A. Kempf [e-mail] Peter J. Prettyman [e-mail] /s/ Elizabeth A. Schuerman Elizabeth A. Schuerman DELANEY & DELANEY LLC 3646 N. Washington Blvd. Indianapolis, Indiana 46205 Tel: [phone] Fax: [phone]

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