Excelsior Printing Company v. Inman et al

Filing 22

AFFIDAVIT in Support re 21 Stipulation to Extend Time to File Response to Complaint. (Balasubramani, Venkat)

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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. DECLARATION OF VENKAT BALASUBRAMANI IN SUPPORT OF THIRD JOINT STIPULATION EXTENDING TIME TO RESPOND TO COMPLAINT I, Venkat Balasubramani, declare the following: 1. I am an attorney, duly licensed to practice law in the State of Washington and the State of California. I have been admitted to practice in this Court pro hac vice. I have personal knowledge of the following facts, and write this Declaration based on my personal knowledge. 2. This Declaration is submitted in support of Plaintiff Excelsior Printing Company and the Defendant Matthew Inman’s Third Joint Stipulation to Extend Time to Respond to Plaintiff’s Complaint. 3. There is good cause for the stipulated extension. The parties are engaged in substantive discussions in an attempt to resolve the case and would like additional time to engage in further discussions. Additionally, counsel for Inman had some travel planned, and counsel for Excelsior has a trial in April that have made settlement discussions somewhat lengthier than they otherwise would have been. Plaintiff Excelsior Printing Company does not object to the extension and joins in the Stipulation. Changing the response deadline for Mr. Inman will not have any effect on the case schedule, as there are currently no case deadlines. I declare under penalty of perjury that the foregoing is true and correct. Executed on April 8, 2013 at Seattle, Washington. /s/ Venkat Balasubramani Venkat Balasubramani 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

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