FotoMedia Technologies, LLC v. AOL, LLC. et al

Filing 39

MOTION for Extension of Time to File Answer re #1 Complaint, Unopposed Motion for Extension of Time for AOL LLC and America Online, Inc. to Answer or Otherwise Respond to Complaint by AOL, LLC., America Online, Inc.. (Attachments: #1 Text of Proposed Order)(Gillam, Harry)

FotoMedia Technologies, LLC v. AOL, LLC. et al

Doc. 39

Case 2:07-cv-00255-TJW-CE

Document 39

Filed 09/06/2007

Page 1 of 2

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION FOTOMEDIA TECHNOLOGIES, LLC, Plaintiff, vs. AOL LLC, AMERICA ONLINE, INC., PHOTOBUCKET.COM, INC., SHUTTERFLY, INC., CNET NETWORKS, INC., AND YAHOO! INC., Defendants. UNOPPOSED MOTION FOR EXTENSION OF TIME FOR AOL LLC AND AMERICA ONLINE, INC. TO ANSWER OR OTHERWISE RESPOND TO COMPLAINT C.A. No. 2:07-CV-255-TJW JURY TRIAL DEMANDED

TO THE HONORABLE JUDGE OF SAID COURT:
1. Defendants AOL LLC and AMERICA ONLINE, INC. hereby move the Court to

extend the time within which Defendants are required to move, answer, or otherwise respond to Plaintiff FOTOMEDIA TECHNOLOGIES, LLC's Complaint up to and including September 17, 2007. 2. Good cause exists for the granting of this motion and the motion is made for the

reason and on the grounds that the additional time is necessary in order to allow counsel to adequately confer with their clients and respond appropriately to Plaintiff's Complaint. WHEREFORE, Defendants AOL LLC and AMERICA ONLINE, INC. respectfully pray that the time to answer or otherwise move or respond to Plaintiff's Complaint be extended until September 17, 2007.

Dockets.Justia.com

Case 2:07-cv-00255-TJW-CE

Document 39

Filed 09/06/2007

Page 2 of 2

Dated: September 6, 2007

Respectfully submitted, GILLAM & SMITH, LLP /s/ Harry L. Gillam, Jr. State Bar No. 07921800 Melissa R. Smith State Bar No. 24001351 GILLAM & SMITH, L.L.P. 303 South Washington Avenue Marshall, TX 75670 Telephone: [phone] Facsimile: [phone] ATTORNEYS FOR DEFENDANTS AOL LLC AND AMERICA ONLINE, INC.

CERTIFICATE OF CONFERENCE The undersigned hereby certifies that counsel for Defendants and counsel for Plaintiff conferred on September 4, 2007 and Plaintiff does not oppose this motion. /s/ Harry L. Gillam, Jr.

CERTIFICATE OF SERVICE The undersigned hereby certifies that the foregoing document was filed electronically in compliance with Local Rule CV-5(a). As such, this motion was served on all counsel who have consented to electronic service. Local Rule CV-5(a)(3)(A). Pursuant to Fed. R. Civ. P. 5(d) and Local Rule CV-5(e), all other counsel of record not deemed to have consented to electronic service were served with a true and correct copy of the foregoing by certified mail, return receipt requested, on this 6th day of September, 2007. /s/ Harry L. Gillam, Jr.