Excelsior Printing Company v. Inman et al

Filing 28

Assented to MOTION for Extension of Time to 07/03/2013 to File Answer by Matthew Inman.(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.
DEFENDANT MATTHEW INMAN’S ASSENTED-TO MOTION FOR EXTENSION OF
TIME TO ANSWER OR OTHERWISE RESPOND TO COMPLAINT
Defendant Matthew Inman (“Inman”) respectfully requests that this Court grant an
extension of time, up to and including July 3, 2013, to answer or otherwise respond to the
Complaint.
Plaintiff filed the Complaint on November 20, 2012. Plaintiff and Inman have previously
filed, and the Court has granted, three previous requests for extensions of the deadline to answer
or otherwise respond to the Complaint. Excelsior and Inman are still engaged in substantive
discussions to try 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, the Court recently granted (Dkt.
No. 27) an assented-to motion filed by Defendant Papyrus-Recycled Greetings, Inc, for an
extension of time, up to and including July 3, 2013, to answer or otherwise respond to the

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Complaint. Therefore, extending the deadline for Inman to the same date would bring all parties
on the same timeline for responding to the Complaint.
Plaintiff and Defendant Papyrus-Recycled Greetings, Inc., through counsel, have
assented to this motion.
Respectfully submitted, this 8th day of May, 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/ 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 PURSUANT TO LOCAL RULE 7.1(A)(2)
I, Venkat Balasubramani, counsel for Defendant Matthew Inman, hereby certify that I
have conferred with counsel for Plaintiff, and counsel for Defendant Papyrus-Recycled
Greetings, Inc. about this motion, and both parties have assented to this motion.
/s/ Venkat Balasubramani
Venkat Balasubramani

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CERTIFICATE OF SERVICE
I hereby certify that this document was filed on May 8, 2013, through the Court’s
CM/ECF system. A copy 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 nonregistered participants on the above date.
/s/ Venkat Balasubramani
Venkat Balasubramani

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