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

Filing 75

Second MOTION for extension of time (Unopposed) for All Defendants to Respond to Plaintiff's Motion for Entry of Protective Order Governing Discovery That Includes An In-House Counsel Provision by Defendants theglobe.com, Inc., Voiceglo Holdings, Inc. (Nehrbass, Scott)

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

Doc. 75

Case 2:05-cv-02433-JWL

Document 75

Filed 02/27/2006

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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., and VONAGE AMERICA, INC., Defendants. ) ) ) ) ) ) ) ) ) ) ) )

CASE NO. 05-2433 JWL

SECOND UNOPPOSED MOTION FOR AN EXTENSION OF TIME FOR ALL DEFENDANTS TO RESPOND TO PLAINTIFF'S MOTION FOR ENTRY OF PROTECTIVE ORDER GOVERNING DISCOVERY THAT INCLUDES AN IN-HOUSE COUNSEL PROVISION COMES NOW Defendants theglobe.com, Inc. and Voiceglo Holdings, Inc. and hereby move the Court to extend the time for all defendants to respond to Plaintiff's Motion for Entry of Protective Order Governing Discovery that Includes an In-House Counsel Provision. In support, Defendants state as follows: 1. Plaintiff Sprint filed its Motion for Entry of Protective Order Governing

Discovery that Includes an In-House Counsel Provision on February 6, 2006 ("Motion") (Doc. 55). Pursuant to Local Rule 6.1(d)(1), the original date for responding to said Motion was February 21, 2006. 2. Defendants requested and were granted one prior extension of time to respond to

the Motion, and that extension expires today. 3. Counsel for Plaintiff and both Defendants have been working in good faith to

come to an agreement with regard to a Protective Order. The parties are currently in agreement regarding the language of most of the provisions of the proposed Protective Order submitted by

Dockets.Justia.com

Case 2:05-cv-02433-JWL

Document 75

Filed 02/27/2006

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Sprint. However, the parties continue to work on a few provisions of the Protective Order regarding access to confidential information by in-house counsel. The parties anticipate reaching a resolution by the end of this week. 4. Counsel for all Defendants have conferred with counsel for Sprint, and Sprint's

counsel does not oppose this request for an extension of time. 5. respond. WHEREFORE, for the foregoing reasons, it is respectfully requested that the Court enter an Order granting all Defendants until March 3, 2006 to respond to Plaintiff's Motion. FOULSTON SIEFKIN LLP By_/s/ Scott C. Nehrbass James D. Oliver (#8604) Scott C. Nehrbass ( #16285) 40 Corporate Woods, Suite 1050 9401 Indian Creek Parkway Overland Park, Kansas 66210 Telephone: [phone] Fax: [phone] Email: [e-mail] Email: [e-mail] James W. Dabney (admitted pro hac vice) Henry C. Lebowitz (admitted pro hac vice) Malcolm J. Duncan (admitted pro hac vice) FRIED, FRANK, HARRIS, SHRIVER & JACOBSON LLP One New York Plaza New York, New York 10004 Telephone: [phone] Fax: [phone] Email: [e-mail] Email: [e-mail] Email: [e-mail] ATTORNEYS FOR DEFENDANTS THEGLOBE.COM, INC. AND VOICEGLO HOLDINGS, INC. It is requested that all Defendants be allowed until Friday, March 3, 2006 to

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Case 2:05-cv-02433-JWL

Document 75

Filed 02/27/2006

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Don R. Lolli Patrick J. Kaine DYSART TAYLOR LAY COTTER & MCMONIGLE, P.C. 4420 Madison Avenue Kansas City, MO 64111 Telephone: [phone] Fax: [phone] [e-mail] [e-mail] Patrick D. McPherson Patrick C. Muldoon DUANE MORRIS, LLP 1667 K Street, N.W. Washington, DC 20006-1608 Telephone: [phone] Fax: [phone] [e-mail] [e-mail] ATTORNEYS FOR DEFENDANT VONAGE HOLDINGS CORPORATION AND VONAGE AMERICA, INC.

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Case 2:05-cv-02433-JWL

Document 75

Filed 02/27/2006

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CERTIFICATE OF SERVICE I hereby certify that on this 27th day of February, 2006, I electronically filed the above and foregoing with the clerk of the court by using the CM/ECF system, which will send a notice of electronic filing to the following: B. Trent Webb [e-mail] Adam P. Seitz [e-mail] Eric A. Buresh [e-mail] Shook Hardy & Bacon L.L.P. 2555 Grand Blvd. Kansas City, MO 64108-2613 Telephone: [phone] Fax: [phone] ATTORNEYS FOR PLAINTIFF SPRINT COMMUNICATIONS COMPANY L.P. Don R. Lolli [e-mail] Patrick J. Kaine [e-mail] Dysart Taylor Lay Cotter & McMonigle, P.C. 4420 Madison Avenue Kansas City, MO 64111 Telephone: [phone] Fax: [phone] Patrick D. McPherson [e-mail] Patrick C. Muldoon [e-mail] Duane Morris, LLP 1667 K Street, N.W. Washington, DC 20006-1608 Telephone: [phone] Fax: [phone] ATTORNEYS FOR DEFENDANT VONAGE HOLDINGS CORPORATION AND VONAGE AMERICA, INC. /s/ Scott C. Nehrbass Attorney for Defendants Theglobe.com, Inc. and Voiceglo Holdings, Inc.

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