Minerva Industries, Inc. v. Motorola, Inc. et al

Filing 92

MOTION for Extension of Time to File Answer re 1 Complaint,,,,, [Unopposed] by Dobson Cellular Systems Inc. (Attachments: # 1 Text of Proposed Order)(Jones, Michael)

Minerva Industries, Inc. v. Motorola, Inc. et al

Doc. 92

Case 2:07-cv-00229-TJW

Document 92

Filed 10/15/2007

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION MINERVA INDUSTRIES, INC. v. 1. MOTOROLA, INC.; et al § § § CIVIL ACTION NO. 2:07-cv-229[TJW] § § JURY DEMAND

DEFENDANT DOBSON CELLULAR SYSTEMS, INC.'S UNOPPOSED MOTION FOR EXTENSION OF TIME IN WHICH TO ANSWER, MOVE, OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT Defendant DOBSON CELLULAR SYSTEMS, INC. ("DOBSON") (which Plaintiff incorrectly identified as DOBSON CELLULAR SYSTEMS d/b/a CELLULAR ONE in its Complaint), without waiving any defenses or any matters that might be presented pursuant to FEDERAL RULE OF CIVIL PROCEDURE 12(b) or any other rule or law, files this unopposed motion for extension of time in which to answer, move, or otherwise respond to Plaintiff MINERVA INDUSTRIES, INC. and would respectfully show the Court as follows: DOBSON has requested and Plaintiff has agreed to an extension of DOBSON'S time to respond in any manner whatsoever including answer, motion or other pleading of any type to Plaintiff's Complaint. Specifically, DOBSON requests, and MINERVA INDUSTRIES, INC. does not oppose, an additional extension of time up to and including January 7, 2008. A proposed Order granting this unopposed motion is attached for the Court's convenience. Dated: October 15, 2007 Respectfully submitted, By: /s/ Michael E. Jones Michael E. Jones State Bar No. 10929400 POTTER MINTON A Professional Corporation 110 N. College, Suite 500 (75702) P. O. Box 359 Tyler, Texas 75710 [phone]
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Dockets.Justia.com

Case 2:07-cv-00229-TJW

Document 92

Filed 10/15/2007

Page 2 of 2

[phone] (Facsimile) [e-mail] OF COUNSEL Charles L. McLawhorn, III [e-mail] MCAFEE & TAFT A PROFESSIONAL CORPORATION 10th Floor, Two Leadership Square, 211 N. Robinson Oklahoma City, Oklahoma 73102 Tel: [phone] Fax: [phone] ATTORNEYS FOR DEFENDANT DOBSON CELLULAR SYSTEMS, INC. CERTIFICATE OF SERVICE I hereby certify that all counsel of record who have consented to electronic service are being served with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3) on this the 15th day of October, 2007. Any other counsel of record will be served by first class U.S. mail on this same date. /s/ Michael E. Jones Michael E. Jones

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