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

Filing 328

MOTION for Leave to file Response Out of Time by Defendants/Counter Claimants Vonage America, Inc., Vonage Holdings Corp. (Campbell, Terrence)

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

Doc. 328

Case 2:05-cv-02433-JWL

Document 328

Filed 08/24/2007

Page 1 of 3

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. ) ) __________________________________________) DEFENDANTS' MOTION FOR LEAVE TO FILE RESPONSE OUT OF TIME It appears that defendants response to plaintiffs' motions in limine will not be filed timely. Accordingly, defendants request one extra hour to file their response. Such relief is in order because plaintiffs will not suffer any prejudice from the extention. Due to the impending due time of the motion, defendants do not have an opportunity to confer with plaintiff concerning the plaintiff's position. WHEREFORE, Vonage respectfully requests that the Court enter an order granting it leave to file its Response to Sprint's Motions in Limine out of time and grant such other and further relief to which it may justly be entitled.

Dockets.Justia.com

Case 2:05-cv-02433-JWL

Document 328

Filed 08/24/2007

Page 2 of 3

Respectfully submitted, BARBER EMERSON, L.C. By: s/ Terrence J. Campbell Terrence J. Campbell - 18377 [e-mail] Catherine C. Theisen - 22360 [e-mail] 1211 Massachusetts Street P.O. Box 667 Lawrence, KS 66044 [phone] [phone] Facsimile

August 24, 2007

Patrick D. McPherson Barry Golob Donald R. McPhail Duane Morris LLP 1667 K Street N.W. Washington, DC 20006-1608 202-776-7800 [e-mail] [e-mail] [e-mail] Attorneys for Defendants Vonage America, Inc. and Vonage Holdings Corp.

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Case 2:05-cv-02433-JWL

Document 328

Filed 08/24/2007

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify on August 24, 2007, that a copy of the foregoing Motion for Leave to File Response out of time was filed electronically, with a notice of case activity to be generated and sent electronically by the Clerk of Court to: B. Trent Webb Adam P. Seitz Erick A. Buresh Shook, Hardy & Bacon LLP 2555 Grand Boulevard Kansas City, MO 64108-2613 [e-mail] [e-mail] [e-mail] Attorneys for Plaintiff Sprint Communications Company L.P. Further, such counsel have been provided a copy of the Exhibits to this Motion, which defendants propose to file under seal, via email. s/ Terrence J. Campbell