The Hershey Company v. Hottrix LLC

Filing 14

Joint MOTION for Extension of Time to Case Management Conference by Hottrix LLC. (Attachments: # 1 Proposed Order Proposed Order)(Tribeck, Robert)

The Hershey Company v. Hottrix LLC

Doc. 14

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA THE HERSHEY COMPANY, Plaintiff, v. HOTTRIX LLC, Defendant. | | | | | | | No. 1:10-cv-1178-JEJ JUDGE JOHN E. JONES III

FILED ELECTRONICALLY

JOINT MOTION TO EXTEND CASE MANAGEMENT CONFERENCE Plaintiff, The Hershey Company (the "Plaintiff"), and Defendant, Hottrix, LLC (the "Defendant"), file the within Joint Motion to Extend Case Management Conference and to response to Plaintiff's Complaint as follows: 1. 2. This Action was instituted on June 2, 2010. On June 8, 2010, the Court issued an Order setting a Case

Management Conference for August 31, 2010. 3. Plaintiff maintains that service was effectuated upon Defendant on or

about June 16, 2010. Defendant disputes that proper service was effectuated. 4. In an effort to avoid further delay and dispute regarding whether

service was effectuated, the parties have agreed that counsel for Defendant will

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accept service on behalf of Defendant and that Defendant will respond to Plaintiff's Complaint on or before September 13, 2010. 5. As a result, because counsel has just entered an appearance

concurrently herewith, and because it is anticipated that Defendant will be advancing counterclaims against Plaintiff, the parties request that the Court reschedule the Case Management Conference currently set for August 31, 2010 in order that the pleadings can be closed and the parties can prepare a comprehensive joint case management plan. WHEREFORE, the parties respectfully request that the Court grant the within Order and reschedule the Case Management Conference currently set for August 31, 2010. MCNEES WALLACE & NURICK By: /s/ Harvey Freedenberg Harvey Freedenberg 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 [phone] hfreedenberg@mwn.c o m Paul C. Llewellyn 425 Park Avenue Kaye Scholer LLP New York, NY 10022 [phone] [e-mail] Counsel for Plaintiff RHOADS & SINON LLP By: /s/ Robert J. Tribeck Robert J. Tribeck Pa. I.D. No. 74486 One South Market Square Harrisburg, PA 17108-1146 [phone] [e-mail] Counsel for Defendant

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CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was electronically filed on August 24, 2010 in accordance with the Rules of the United States District Court for the Middle District of Pennsylvania. /s/ Robert J. Tribeck Robert J. Tribeck

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