Excelsior Printing Company v. Inman et al

Filing 30

Fifth MOTION for Extension of Time to August 16, 2013 to File Answer re 1 Complaint, by Matthew Inman. (Attachments: # 1 Text of Proposed Order 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 MOTION FOR EXTENSION OF TIME TO ANSWER OR OTHERWISE
RESPOND
Plaintiff Excelsior Printing Company (“Excelsior”) and Defendants Matthew Inman
(“Inman”) and Papyrus-Recycled Greetings, Inc. (“RPG”) jointly request an extension of the
deadline for Defendants to respond to the Complaint to August 16, 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 previously filed, and the Court granted, a third stipulation
extending Inman’s deadline to answer or otherwise respond to May 6, 2013. Finally, on May 7th
and 13th, 2013, the court issued Orders granting extensions to RPG and Inman up to and
including July 3, 2013.

The parties 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.
Good cause appearing, the parties respectfully request that the Court grant the requested
extension.
Respectfully submitted, this 2nd day of July, 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]

/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]

Attorney for Plaintiff Excelsior Printing Co.

Attorneys for Defendant Matthew Inman
/s/ Nuala Droney
Nuala E. Droney (BBO# 660582)
Robinson & Cole LLP
280 Trumbull Street Hartford, CT 06103
Tel: [phone] Fax: [phone]
Email: [e-mail]
Attorneys for Defendant Papyrus-Recycled
Greetings, Inc.

RULE 7.1 (A)(2) CERTIFICATE
Pursuant to Local Rule 7.1(A)(2), undersigned counsel states that counsel for Matthew Inman
has conferred with counsel for Papyrus- Recycled Greetings, Inc. and counsel for Plaintiff
Excelsior Printing Company on the 2nd day of July 2013, and that all parties assented to this
filing.
/s/ Venkat Balasubramani
Venkat Balasubramani

CERTIFICATE OF SERVICE
I hereby certify that this document filed on July 2, 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