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

Filing 33

Consent MOTION to Amend/Correct 30 Order on Motion to Amend/Correct by Sirsi Corporation. (Attachments: # 1 Text of Proposed Order Proposed Order) (Numbers, Robert)

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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, Second Consent Motion to Modify the Scheduling Order v. Craven-Pamlico-Carteret Library System, Regional Defendant. Plaintiff Sirsi Corporation d/b/a SirsiDynix moves the Court for an Order modifying the Amended Scheduling Order entered in this matter. In support of this motion, SirsiDynix states as follows: 1. On September 6, 2011, the Court entered a scheduling order that set the deadline to complete discovery and mediation on January 31, 2012 and the deadline for dispositive motions on March 1, 2012. 2. On January 11, 2012, the Court entered an Amended Scheduling Order set the deadline to complete discovery on March 16, 2012 and the deadline for dispositive motions on April 16, 2012. On January 19, 2012, the Court entered an Order extending the deadline to complete mediation until March 16, 2012. 3. Since the entry of the January Orders, the parties have made substantial progress towards reaching a mutually agreeable resolution to this matter. However, to date, the parties have been unable to come to an agreement on all issues. The parties are hopeful that with additional time, they will be able to resolve the remaining issues and resolve this matter through a settlement agreement. 1 4. While the parties are hopeful that they will be able to settle this matter, out of an abundance of caution, the parties would also like additional time to complete discovery in the event that attempts to resolve this matter are unsuccessful. 5. The undersigned has conferred with counsel for CPC Regional and can report that CPC Regional consents to the relief sought in this motion. Wherefore, SirsiDynix requests that the court modify the Amended Scheduling Order to extend the deadline to complete discovery and mediation until May 16, 2012 and the deadline to file dispositive motions until June 15, 2012. Dated: March 8, 2012. WOMBLE CARLYLE SANDRIDGE & RICE A Limited Liability Partnership By: /s/ Robert T. Numbers II____________ ROBERT T. NUMBERS, II (State Bar No. 34134) 150 Fayetteville Street, Suite 2100 Post Office Box 831 Raleigh, North Carolina 27602 (919) 755-2100/(919) 755-6067 (facsimile) Attorney for Plaintiff 2 CERTIFICATE OF SERVICE This is to certify that 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: lwbettis@hotmail.com Attorney for Defendant Dated: March 8, 2012. WOMBLE CARLYLE SANDRIDGE & RICE A Limited Liability Partnership By: /s/ Robert T. Numbers II____________ ROBERT T. NUMBERS, II (State Bar No. 34134) 150 Fayetteville Street, Suite 2100 Post Office Box 831 Raleigh, North Carolina 27602 (919) 755-2100 (919) 755-6067 (facsimile) Attorney for Plaintiff 3

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