Wolf v. Brightroom, Inc. et al

Filing 12

Consent MOTION for Extension of Time to File Answer re 1 Complaint, Move, or Otherwise Respond by SmugMug, Inc.. (Attachments: # 1 Text of Proposed Order)(DeVasto, Diane)

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Wolf v. Brightroom, Inc. et al Doc. 12 Case 2:07-cv-00238-DF Document 12 Filed 08/22/2007 Page 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION § § CIVIL ACTION NO. 2:07cv238[DF] v. § BRIGHTROOM, INC.; ISLAND § PHOTOGRAPHY, INC.; ELIZABETH § DEMAND FOR JURY TRIAL M. KREUTZ; BIRD'S EYE VIEW, INC.; § DIGILABS, INC.; PRINTROOM, INC.; § SMUGMUG, INC.; AND HOUR § PHOTOS, INC., d/b/a MASTER PHOTOS U.S.A. § DEFENDANT SMUGMUG, INC.'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO ANSWER, MOVE, OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT Defendant SmugMug, Inc. ("SmugMug"), 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 Peter H. Wolf's ("Wolf") Complaint and would respectfully show the Court as follows: SmugMug has requested and Wolf has agreed to an additional extension of SmugMug's time to respond in any manner whatsoever including answer, motion, or other pleading of any type to Plaintiff's Complaint up to and including September 27, 2007. A proposed Order granting this unopposed motion is attached for the Court's convenience. PETER H. WOLF {A53\7808\0001\W0334471.1 } Dockets.Justia.com Case 2:07-cv-00238-DF Document 12 Filed 08/22/2007 Page 2 of 2 Dated: August 22, 2007 Respectfully submitted, /s/ Diane V. DeVasto Diane V. DeVasto State Bar No. 05784100 POTTER MINTON A Professional Corporation 110 N. College, Suite 500 (75702) P. O. Box 359 Tyler, Texas 75710 (903) 597-8311 (903) 593-0846 (Facsimile) dianedevasto@potterminton.com Paul J. Andre PAndre@perkinscoie.com PERKINS COIE, LLP 101 Jefferson Drive Menlo Park, California 94025 (650) 838-4300 (650) 838-4350 (Facsimile) ATTORNEYS FOR DEFENDANT SMUGMUG, 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 22nd day of August 2007. Any other counsel of record will be served by first class U.S. mail on this same date. /s/ Diane V. DeVasto Diane V. DeVasto {A53\7808\0001\W0334471.1 }

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