Excelsior Printing Company v. Inman et al

Filing 21

STIPULATION Extending time to file response to complaint by Matthew Inman. (Attachments: # 1 Text of Proposed Order)(Balasubramani, Venkat) Modified on 4/16/2013 (Lindsay, Maurice).

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.

THIRD 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 May 6, 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. Additionally, Excelsior and Inman previously filed, and the Court
granted, a second stipulation extending Inman’s deadline to answer or otherwise respond to April
12, 2013.
Excelsior and Inman are still 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. Additionally, one of the other defendants in the case currently has a deadline of May 6,
2013 to file an answer or responsive pleading, so extending the deadline for Inman to the same
date would bring all parties on the same timeline for responding to Excelsior’s Complaint.
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 8th day of April, 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 April 8, 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