Actus, LLC v. Bank of America Corp. et al

Filing 118

Unopposed MOTION for Extension of Time to File Answer re 4 Amended Complaint by Walt Disney Co. (Attachments: # 1 Text of Proposed Order)(Bunt, Robert)

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION ACTUS, LLC v. BANK OF AMERICA CORP. BLAZE MOBILE, INC. CAPITAL ONE FINANCIAL CORP. ENABLE HOLDINGS, INC. GOOGLE, INC. GREEN DOT CORP. JAVIEN DIGITAL PAYMENT SOLUTIONS, INC. JP MORGAN CHASE & CO. MASTERCARD INTERNATIONAL, INC. META FINANCIAL GROUP, INC. M&T BANK CORP. OBOPAY, INC. SONIC SOLUTIONS VISA, INC. VIVENDI UNIVERSAL U.S. HOLDING CO. VIVENDI UNIVERSAL, SA WAL-MART STORES, INC. THE WALT DISNEY STORES, INC. THE WESTERN UNION CO. WILDTANGENT, INC. AGILECO CIVIL ACTION NO. 2:09-cv-102 (TJW) Jury Trial Demanded THE WALT DISNEY CO.'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO ANSWER, MOVE OR OTHERWISE RESPOND TO PLAINTIFF'S FIRST AMENDED COMPLAINT Defendant The Walt Disney Co. 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 Actus, LLC's First Amended Complaint and would respectfully show the Court as follows: The Walt Disney Co. has requested and Plaintiff has agreed to a thirty (30) day extension of The Walt Disney Co.'s time to respond in any manner whatsoever including answer, motion or other pleading of any type to Plaintiff's First Amended Complaint. Specifically, The Walt Disney Co. requests, and Plaintiff does not oppose, an extension of time up to and including August 5, 2009. A proposed Order granting this unopposed motion is attached for the Court's convenience. Respectfully submitted, /s/ Robert Christopher Bunt Robert Christopher Bunt State Bar No. 00787165 PARKER, BUNT & AINSWORTH, P.C. 100 E. Ferguson, Suite 1114 Tyler, Texas 75702 903/531-3535 903/533-9687 - Facsimile E-mail: Attorneys for Defendant The Walt Disney Co. CERTIFICATE OF SERVICE I hereby certify that the all counsel of record, who are deemed to have consented to electronic service are being served this 6th day of July 2009, with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3). Any other counsel of record will be served by electronic mail, facsimile transmission and/or first class mail on this same date. /s/ Robert Christopher Bunt ROBERT CHRISTOPHER BUNT 2

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