Excelsior Printing Company v. Inman et al

Filing 14

STIPULATION Extending Time to Respond to Complaint by Matthew Inman. (Attachments: # 1 Text of Proposed Order)(Balasubramani, Venkat)

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS
Western Division
EXCELSIOR PRINTING
COMPANY,
Civil Action No. 3:12-cv-30200-MAP
Plaintiff,
v.
MATTHEW INMAN
and PAPYRUS-RECYCLED
GREETINGS, INC.,
Defendants.
JOINT STIPULATION EXTENDING TIME TO RESPOND TO PLAINTIFF’S
COMPLAINT
Plaintiff Excelsior Printing Company and Defendant Matthew Inman stipulate, subject to
Court approval, to extend the deadline for Mr. Inman to answer or otherwise respond to
Plaintiff’s Complaint to February 27, 2013.
Excelsior filed the Complaint on November 20, 2012, and Defendant Inman’s response to
Plaintiff’s Complaint is currently due on January 28, 2013. The proposed extension will not
affect any currently pending deadlines, as there are no other dates (e.g., hearing dates, discovery
cut-off dates, hearing deadlines, pre-trial conference dates, or trial dates) currently set in this
matter.
As set forth in the Declaration of Venkat Balasubramani (submitted herewith), the
Defendant acted diligently in seeking the present extension and there is good cause for granting
it. A proposed order is attached hereto.
Respectfully submitted, this 25th day of January, 2013.

/s/ Venkat Balasubramani
Venkat Balasubramani (pro hac vice)
Focal PLLC
800 Fifth Avenue, Suite 4100
Seattle, Washington 98104
Tel: [phone]
Fax: [phone]
Email: [e-mail]

/s/ Christopher M. Hennessey
Christopher M.Hennessey
Cohen Kinne Valicenti & Cook, LLP
28 North Street
3rd Floor
Pittsfield, MA 01201
413-443-9399
Email: [e-mail]
Attorney for Plaintiff Excelsior Printing Co.

/s/ Matthew Saunders
Aaron Silverstein (BBO# 660716)
Arpiar M. Saunders (BBO# 664997)
Saunders & Silverstein LLP
14 Cedar Street, Suite 224
Amesbury, MA 01913
Tel: [phone]
Fax: [phone]
Attorneys for Defendant Matthew Inman

CERTIFICATE OF SERVICE
I hereby certify that this document filed on January 25, 2013, through the ECF system
will be sent electronically to the registered participants as identified on the Notice of Electronic
Filing (NEF) and paper copies will be sent to those indicated as non-registered participants on
the above date.
/s/ Venkat Balasubramani
Venkat Balasubramani