Beneficial Innovations, Inc. v. Careerbuilder, LLC et al

Filing 25

Unopposed MOTION for Extension of Time to File Answer , Move or Otherwise Respond to Plaintiff, Beneficial Innovations, Inc.'s Complaint by YouTube, LLC, Google, Inc.. (Attachments: # 1 Text of Proposed Order)(Smith, Melissa)

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION BENEFICIAL INNOVATIONS, INC., Plaintiff, VS. COMCAST CORPORATION, et al., Defendants. Civil Action No: 2:09-cv-175-TJW DEFENDANTS GOOGLE INC.' S AND YOUTUBE, LLC'S UNOPPOSED MOTION TO EXTEND TIME TO ANSWER, MOVE OR OTHERWISE RESPOND TO PLAINTIFF BENEFICIAL INNOVATIONS, INC.'S COMPLAINT TO THE HONORABLE JUDGE OF SAID COURT: 1. Defendants Google Inc. and YouTube, LLC hereby move the Court to extend the time within which Defendant is required to move, answer, or otherwise respond to Plaintiff Beneficial Innovations, Inc.'s Complaint up to and including November 4, 2009. 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 client and respond appropriately to Beneficial Innovations, Inc.'s complaint. 3. This extension is not sought for the purposes of delay and specifically should not be the basis to delay any scheduling conference in this cause. WHEREFORE, Defendants Google Inc. and YouTube, LLC respectfully pray that the time to answer or otherwise move or respond to Beneficial Innovations, Inc.'s Complaint be enlarged until November 4, 2009. Date: October 2, 2009 Respectfully submitted, /s/ Melissa R. Smith Melissa Richards Smith LEAD ATTORNEY State Bar No. 24001351 Gillam & Smith, LLP 303 South Washington Avenue Marshall, TX 75670 Telephone: (903) 934-9257 E-mail: melissa@gillamsmithlaw.com CERTIFICATE OF CONFERENCE The undersigned hereby certifies that counsel for Defendants, Google Inc. and YouTube, LLC, and counsel for Plaintiff, Beneficial Innovations, Inc. conferred on October 2, 2009, and Plaintiff does not oppose this motion. /s/ Melissa R. Smith CERTIFICATE OF SERVICE The undersigned hereby certifies that on October 2, 2009, the foregoing document was filed electronically in compliance with Local Rule CV-5(a). As such, this notice was served on all counsel who have consented to electronic service. Local Rule CV-5(a)(3)(A). Any other counsel of record will be served by electronic mail, facsimile transmission and/or first class mail on this same date. /s/ Melissa R. Smith -2-

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