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

Filing 35

Unopposed MOTION for Extension of Time to File Response as to 33 Memorandum in Support of Motion, 32 MOTION to Sever and Drop Misjoined Parties by Plaintiff Sprint Communications Company LP.(Seitz, Adam)

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

Doc. 35

Case 2:05-cv-02433-JWL

Document 35

Filed 12/19/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS SPRINT COMMUNICATIONS COMPANY L.P., ) ) Plaintiff, ) ) v. ) ) THEGLOBE.COM, INC., ) VOICEGLO HOLDINGS, INC., ) VONAGE HOLDINGS CORP., ) VONAGE AMERICA, INC., ) ) Defendants. ) __________________________________________)

Case No. 05-2433-JWL-DJW

UNOPPOSED MOTION FOR EXTENSION OF TIME FOR PLAINTIFF TO RESPOND TO DEFENDANTS THEGLOBE.COM, INC. AND VOICEGLO HOLDING, INC.'S MOTION TO SEVER Plaintiff Sprint Communications Company, L.P. ("Sprint"), by and through its undersigned counsel, respectfully requests an extension up to and including January 13, 2006 in which to file a Response to Defendants Theglobe.com, Inc.'s and Voiceglo Holdings, Inc.'s Motion to Drop Misjoined Parties and Sever Claims for Separate Proceedings. In support of its Motion, Sprint respectfully shows the Court as follows: 1. Defendants' motion was filed on Friday, December 16, 2005. A response

to Defendants' motion is due on December 30, 2005. 2. Plaintiff seeks an extension up to and including January 13, 2006 in which

to file a response to Defendants' motion. 3. Counsel for Plaintiff has conferred with Counsel for Defendants.

Defendants' counsel does not object to this extension. 4. There is no prejudice to any party as a result of this request. 1

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Case 2:05-cv-02433-JWL

Document 35

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5.

This Motion is not being filed for the purpose of delay.

WHEREFORE, Plaintiff Sprint Communications Company, L.P. moves for an extension up to and including January 13, 2006 in which to file a Response to Defendants' Motion to Drop Misjoined Parties and Sever Claims for Separate Proceedings. A Proposed Order has been submitted to the Court pursuant to the ECF Guidelines. Dated: December 19, 2005 Respectfully submitted, /s/ Adam P. Seitz B. Trent Webb, KS Bar No. 15965 Adam P. Seitz, KS Bar No. 21059 Eric A. Buresh, KS Bar No. 19895 SHOOK, HARDY & BACON LLP 2555 Grand Blvd. Kansas City, Missouri 64108-2613 816-474-6550 Telephone [phone] Facsimile ATTORNEYS FOR PLAINTIFF SPRINT COMMUNICATIONS COMPANY L.P.

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Case 2:05-cv-02433-JWL

Document 35

Filed 12/19/2005

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CERTIFICATE OF SERVICE I hereby certify that on the 19th day of December, 2005, a copy of the above and foregoing UNOPPOSED MOTION FOR EXTENSION OF TIME FOR PLAINTIFF TO REPLY TO DEFENDANTS THEGLOBE.COM, INC. AND VOICEGLO HOLDING, INC.'S MOTION TO DROP MISJOINED PARTIES AND SEVER CLAIMS FOR SEPARATE PROCEEDINGS was e-filed with the Court using the CM/ECF system which sent notification to all parties entitled to notice including: James D. Oliver Scott C. Nehrbass Foulston Siefkin LLP 40 Corporate Woods Suite 1050 9401 Indian Creek Parkway Overland Park, Kansas 66210 James W. Dabney Henry C. Lebowitz Malcolm J. Duncan Fried, Frank, Harris, Shriver & Jacobson LLP One New York Plaza New York, New York 10004 ATTORNEYS FOR DEFENDANTS THEGLOBE.COM, INC. AND VOICEGLO HOLDINGS, INC. __/s/ Adam P. Seitz__________ Attorney for Plaintiff

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