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

Filing 165

Unopposed MOTION for Extension of Time to File Answer to First Amended Complaint by JP Morgan Chase & Co.. (Attachments: # 1 Text of Proposed Order)(Yarbrough, Herbert)

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION ACTUS, LLC, § § Plaintiff, § § 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.; § JPMORGAN CHASE & CO.; § MASTERCARD INTERNATIONAL, § INC.; META FINANCIAL GROUP, § INC.; M&T BANK CORP.; OBOPAY, § INC.; SONIC SOLUTIONS; VISA, § INC.; VIVENDI, SA; WAL-MART § STORES, INC.; THE WALT DISNEY § § CO.; THE WESTERN UNION CO.; WILDTANGENT, INC.; AGILECO, § § Defendants. § CIVIL ACTION NO. 2:09-CV-102

JURY TRIAL DEMANDED

Unopposed Motion for Third Extension of Time in Which to Answer or Otherwise Respond to Plaintiff's First Amended Complaint Defendant, JP Morgan Chase & Co. ("JP Morgan"), without waiving any defenses set forth in Fed. R. Civ. P. 12, moves the Court for a third extension of time in which to answer or otherwise respond to Plaintiff's First Amended Complaint: 1. Defendant moves for an extension of time through and including

August 14, 2009. As set forth in the above caption, this motion is unopposed.

2.

Defendant respectfully submits that good cause exists and seeks

the requested extension in order to adequately and properly respond to Plaintiff's First Amended Complaint. Wherefore, Defendant, JP Morgan Chase & Co., moves for an extension of time to and including August 14, 2009 in which to answer, move or otherwise respond to Plaintiff's First Amended Complaint. DATED: August 6, 2009 Respectfully submitted, /s/ Trey Yarbrough Trey Yarbrough Bar No. 22133500 YARBROUGH WILCOX, PLLC 100 E. Ferguson St., Ste. 1015 Tyler, TX 75702 [phone] Fax: [phone] [e-mail] Attorney for Defendant, JP Morgan Chase & Co. Certificate of Service The undersigned hereby certifies that all counsel of record who are deemed to 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 6th day of August, 2009. All other counsel not deemed to have consented to service in such manner will be served via facsimile transmission and/or first class mail. /s/ Trey Yarbrough Trey Yarbrough