SuccessFactors, Inc. v. Softscape, Inc., et al

Filing 3

NOTICE of Appearance and Motion for Extension of Time by Luis F. Del-Valle-Emmanuelli on behalf of New Millenium Shoe Company (Del-Valle-Emmanuelli, Luis)

SuccessFactors, Inc. v. Softscape, Inc., et al

Doc. 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO SUCCESSFACTORS, INC., Plaintiffs, v. SOFTSCAPE, INC., and DOES 1-10, inclusive, Defendants. CIVIL NO. 08-00155 (FAB)

NOTICE OF APPEARANCE AND MOTION FOR AN EXTENSION OF TIME
TO THE HONORABLE COURT: COMES NOW third-party New Millenium Shoe ("NMS") and through the undersigned attorney very respectfully states and prays: 1. Third-party NMS has retained undersigned counsel to represent it in the captioned

matter. It is respectfully requested that notice be taken of the undersigned's appearance and that all documents, papers and pleadings be served at the address below: Luis F. del Valle-Emmanuelli P.O. Box 79897 Carolina, Puerto Rico 00984-9897 Tel [phone] Fax [phone] [e-mail] 2. Undersigned counsel will jointly represent NMS in the captioned matter with: Luis F. Juarbe-Jiménez Báez & Juarbe 618 Barbosa Avenue Barbosa Building, Suite 103 Hato Rey, Puerto Rico 00918 Tel [phone] Fax [phone] lfjuarbe@baez&juarbe.com 3. NMS is the target of a motion filed by SuccessFactors, Inc., on August 11, 2008

(docket entry 1), seeking to compel NMS to produce a myriad of documents. The opposition

Dockets.Justia.com

response is due by August 27, 2008. 4. NMS respectfully requests an extension of time of ten (10) days so the

undersigned may have sufficient time to fully review the matter and be in a position to draft a response brief on its behalf. NMS respectfully submits that the extension of time requested will not cause prejudice or unduly delay these proceedings, and will allow the third-party's counsel to become acquainted with the issues. WHEREFORE, third-party New Millenium Shoe very respectfully requests that notice be taken of the appearance of both their counsel and further requests that an extension of ten (10) days, or until September 4, 2008, be granted to file an opposition to SuccessFactors, Inc.'s motion to compel (docket entry 1). I HEREBY CERTIFY that on August 20, 2008, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system, which will send notification of such filing to Roberto A. Cámara-Fuertes, Fiddler, González & Rodríguez, P.O. Box 363507, San Juan, Puerto Rico 00936-3507 and all CM/ECF participants in the case. RESPECTFULLY SUBMITTED. In San Juan, Puerto Rico this 20th day of August, 2008. DEL VALLE-EMMANUELLI LAW OFFICES P.O. Box 79897 Carolina, Puerto Rico 00984-9897 Tel. [phone] Fax [phone] S/Luis F. del Valle_________________ LUIS F. DEL VALLE-EMMANUELLI USDC NO. 209514 [e-mail]

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