Sirsi Corporation v. Craven-Pamlico-Carteret Regional Library System

Filing 12

MOTION for Extension of Time to File Response/Reply as to 7 First MOTION to Dismiss Pursuant to Rule 12 (b)(6)First MOTION to Dismiss Pursuant to Rule 12 (b)(6), 8 Answer to Complaint, Counterclaim by Sirsi Corporation. (Attachments: # 1 Proposed Order) (Numbers, Robert)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF NORTH CAROLINA
EASTERN DIVISION
Civil Action No. 4:11-cv-00059-BO
SIRSI CORPORATION d/b/a
SIRSIDYNIX,
Plaintiff,
v.
CRAVEN-PAMLICO-CARTERET
REGIONAL LIBRARY SYSTEM,
Defendant.

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PLAINTIFF’S MOTION FOR EXTENSION
OF TIME IN WHICH TO RESPOND TO
DEFENDANT’S COUNTERCLAIMS AND
MOTION TO DISMISS

Plaintiff, by and through counsel, moves the Court for an extension of time in which to
reply to Defendant’s Counterclaims and Defendant’s Motion to Dismiss pursuant to Rule 6 of the
Federal Rules of Civil Procedure. In support of this motion, Plaintiff states as follows:
1.

On April 15, 2011, Plaintiff filed a complaint against Defendant.

2.

Defendant filed its Answer and Counterclaims on June 17, 2011.

3.

On June 17, 2011, Defendant filed a Motion to Dismiss.

4.

The deadline for Plaintiff to reply to Defendant’s Counterclaims and Defendant’s

Motion to Dismiss is July 11, 2011.
5.

The time for Plaintiff to reply has not expired.

6.

Plaintiff moves for an extension of time, up to and through July 22, 2011 in which

to file and serve its replies.
7.

Additional time is needed to investigate the claims raised in Defendant’s

Counterclaims and examine the law applicable thereto. Similarly, additional time is necessary to
analyze the law applicable to Defendant’s motion to dismiss and prepare a response.

8.

Counsel for Plaintiff has conferred with Defendant’s counsel and Defendant’s

counsel consents to Plaintiff’s motion for extension of time.
9.

This motion is made in good faith and not for the purpose of delay.

WHEREFORE, Plaintiff requests the Court grant it an extension of time up to and
through July 22, 2011, in which to serve and file its replies to Defendant’s Counterclaims and
Defendant’s Motion to Dismiss.
This the 6th day of July, 2011.

WOMBLE CARLYLE SANDRIDGE & RICE
A Professional Limited Liability Company
By:

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/s/ Robert T. Numbers II________________
ROBERT T. NUMBERS, II
(N.C. State Bar No. 34134)
150 Fayetteville Street, Suite 2100
Post Office Box 831
Raleigh, North Carolina 27602
[phone]
[phone] (facsimile)
Attorney for Plaintiff

CERTIFICATE OF SERVICE
This is to certify that on July 6, 2011, a copy of the foregoing was filed electronically
with the Clerk of Court using the CM/ECF system, which will send notification of such filing to
the following:
Lee W. Bettis , Jr.
The Bettis Law Firm
P. O. Box 848
New Bern, NC 28560
Email: [e-mail]
Attorney for Defendant

WOMBLE CARLYLE SANDRIDGE & RICE
A Professional Limited Liability Company
By:

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/s/ Robert T. Numbers II________________
ROBERT T. NUMBERS, II
(N.C. State Bar No. 34134)
150 Fayetteville Street, Suite 2100
Post Office Box 831
Raleigh, North Carolina 27602
[phone]
[phone] (facsimile)
Attorney for Plaintiff