Sprint Communications Company LP v. Vonage Holdings Corp., et al

Filing 208

Joint MOTION for Extension of Time to File oppositions and replies as to 196 MOTION to Exclude the Opinions of Vonage's Expert Joel M. Halpern, 198 MOTION for Partial Summary Judgment, 200 MOTION for Summary Judgment by Defendants Vonage America, Inc., Vonage Holdings Corp. (Kaine, Patrick)

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Sprint Communications Company LP v. Vonage Holdings Corp., et al Doc. 208 Case 2:05-cv-02433-JWL Document 208 Filed 05/24/2007 Page 1 of 4 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS ___________________________________________ ) SPRINT COMMUNICATIONS COMPANY L.P., ) ) Plaintiff, ) ) Case No. 05-2433-JWL v. ) ) VONAGE HOLDINGS CORP. and ) VONAGE AMERICA, INC. ) ) Defendants. ) ___________________________________________ ) JOINT MOTION TO EXTEND DEADLINES FOR FILING OPPOSITIONS AND REPLIES TO PENDING MOTIONS Plaintiff Sprint Communications Company L.P. ("Sprint") and Defendants Vonage Holdings Corp. and Vonage America, Inc. (collectively "Vonage"), by and through their respective attorneys, jointly move the Court to extend the deadlines for filing oppositions and replies to the parties' respective Motions for Summary Judgment (D.I. 198 and 200) and Sprint's Motion to Exclude the Opinions of Joel M. Halpern (D.I. 196). There will be no prejudice to either party as a result of these extensions, and the extensions are not being sought for vexatious purposes or to delay these proceedings. Moreover, the Court's scheduled trial date of September 4, 2007 remains unchanged. Pursuant to District of Kansas Rule 6.1(a)(1), the undersigned state that the parties have conferred by counsel and that the parties have agreed that these extensions of time are required. Dockets.Justia.com Case 2:05-cv-02433-JWL Document 208 Filed 05/24/2007 Page 2 of 4 Pursuant to Rule 6.1(a)(2), the undersigned state that the current due dates and the requested extensions thereof are shown in the following table: Event Opposition to Motion for Summary Judgment Reply to Opposition to Motion for Summary Judgment Vonage's Opposition to Sprint's Motion to Exclude the Opinions of Joel M. Halpern Sprint's Reply to Vonage's Opposition to Sprint's Motion to Exclude Current Due Date June 7, 2007 Requested Due Date June 11, 2007 July 2, 2007 July 6, 2007 May 28, 2007 June 11, 2007 June 7, 2007 July 6, 2007 Pursuant to Rule 6.1(a)(3), the undersigned state that no extensions have been sought by the parties or granted by this Court for any of these dates. Pursuant to Rule 6.1(a)(4), the undersigned state that the reasons for the requested extensions are as follows: With respect to the Motions for Summary Judgment, the requested extensions are sought so that the due dates will fall after, rather than before, a weekend (June 9-10) and a federal holiday (July 4), respectively. With respect to Sprint's Motion to Exclude the Opinions of Joel M. Halpern, the requested extensions are sought so that the due dates for Vonage's Opposition and -2- Case 2:05-cv-02433-JWL Document 208 Filed 05/24/2007 Page 3 of 4 Sprint's Reply thereto will coincide with the due dates for the parties' respective oppositions to Motions for Summary Judgment and their respective replies. Wherefore, for good cause shown, Sprint and Vonage respectfully request that the Court grant this motion and extend the relevant deadlines. Respectfully submitted this 24th day of May, 2007. /s/ Patrick J. Kaine Patrick J. Kaine KS #15594 Don R. Lolli KS Dist. #70236 Dysart Taylor Lay Cotter & McMonigle P.C. 4420 Madison Avenue Kansas City, Missouri 64111 816-931-2700 pkaine@DysartTaylor.com dlolli@DysartTaylor.com Patrick D. McPherson Barry Golob Donald R. McPhail Patrick C. Muldoon Duane Morris LLP 1667 K Street N.W. Washington, DC 20006-1608 202-776-7800 pdmcpherson@duanemorris.com bgolob@duanemorris.com drmcphail@duanemorris.com Attorneys for Defendants/Counterclaim Plaintiffs Vonage America, Inc. and Vonage Holdings Corp. /s/ Adam P. Seitz -3- Case 2:05-cv-02433-JWL Document 208 Filed 05/24/2007 Page 4 of 4 B. Trent Webb Adam P. Seitz Eric A. Buresh SHOOK, HARDY & BACON LLP 2555 Grand Boulevard Kansas City, MO 64108-2613 Fax: (816) 421-5547 Attorneys for Plaintiff/Counterclaim Defendant Sprint Communications Company L. P. CERTIFICATE OF SERVICE I hereby certify on this 24th day of May, 2007 that a true copy of the Joint Motion to Extend Deadlines for Filing Oppositions and Replies to Pending Motions was sent by electronic mail to: B. Trent Webb Adam P. Seitz Erick A. Buresh SHOOK, HARDY & BACON LLP 2555 Grand Boulevard Kansas City, MO 64108-2613 Fax: (816) 421-5547 Attorneys for Plaintiff/Counterclaim Defendant Sprint Communications Company L. P. /s/ Donald R. McPhail Donald R. McPhail -4-

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