Excelsior Printing Company v. Inman et al
Filing
17
STIPULATION Extending Time to Respond to Plaintiff's Complaint by Matthew Inman. (Attachments: # 1 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.
SECOND JOINT STIPULATION EXTENDING TIME
TO RESPOND TO PLAINTIFF’S COMPLAINT
Plaintiff Excelsior Printing Company (“Excelsior”) and Defendant Matthew Inman
(“Inman”) stipulate, subject to Court approval, to extend the deadline for Inman to answer or
otherwise respond to the Complaint to April 12, 2013.
Excelsior filed the Complaint on November 20, 2012. Excelsior and Inman previously
filed, and the Court granted, a stipulation extending Inman’s deadline to answer or otherwise
respond to February 27, 2013. Excelsior and Inman are engaged in substantive discussions to
resolve the case and would like additional time to engage in further discussions. 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 13th day of February, 2013.
/s/ Venkat Balasubramani
Venkat Balasubramani (pro hac vice)
Focal PLLC
800 Fifth Avenue, Suite 4100
Seattle, Washington 98104
Tel: (206) 529-4827
Fax: (206) 260-3966
Email: venkat@focallaw.com
/s/ Christopher M. Hennessey
Christopher M.Hennessey
Cohen Kinne Valicenti & Cook, LLP
28 North Street
3rd Floor
Pittsfield, MA 01201
413-443-9399
Email: chennessey@cohenkinne.com
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: (978) 463-9100
Fax: (978) 463-9109
Attorneys for Defendant Matthew Inman
CERTIFICATE OF SERVICE
I hereby certify that this document filed on February 13, 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
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