Gooseberry Natural Resources, LLC v. Condesa, Inc. et al

Filing 17

Agreed MOTION for Extension of Time to File Answer re #1 Complaint, by Gooseberry Natural Resources, LLC, RV Media LLC. (Attachments: #1 Text of Proposed Order)(Smith, Melissa)

Gooseberry Natural Resources, LLC v. Condesa, Inc. et al

Doc. 17

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION GOOSEBERRY NATURAL RESOURCES, LLC, Plaintiff, Civil Action No. 2:10-CV-210-TJW v. CONDESA, INC., MASS MEDIA DISTRIBUTION, LLC MEK ENTERPRISES d/b/a ERELEASES.COM, PROVEN WAYS, INC., PR WORLDWIDE, INC., and RV MEDIA, LLC d/b/a PR 18 NETWORK, Defendants. AGREED MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S COMPLAINT FOR PATENT INFRINGEMENT Plaintiff, Gooseberry Natural Resources, LLC, and Defendant RV Media, LLC d/b/a PR 18 Network (pro se) respectfully move this Court for an extension of time for Defendant RV Media, LLC d/b/a PR 18 Network to respond to Plaintiff's Complaint for Patent Infringement, and would show the Court as follows: 1. 2. On June 24, 2010, Plaintiff filed its Complaint for Patent Infringement. On June 28, 2010, RV Media, LLC d/b/a PR 18 Network was served with JURY TRIAL DEMANDED

Plaintiff's Complaint. 3. Pursuant to Federal Rules of Civil Procedure 12(a)(1)(A) and 6(d), RV Media,

LLC d/b/a PR 18 Network's response to Plaintiff's Complaint is due on July 19, 2010.

Dockets.Justia.com

4.

On July 13, 2010, RV Media, LLC d/b/a PR 18 Network (pro se) sought a 30-day

extension from Plaintiff to respond to Plaintiff's Complaint, and Plaintiff agreed to a 30-day extension, until August 18, 2010. WHEREFORE, Plaintiff, Gooseberry Natural Resources, LLC, and Defendant RV Media, LLC d/b/a PR 18 Network (pro se) request that the Court enter an order extending the time for Defendant RV Media, LLC d/b/a PR 18 Network to answer Plaintiff's Complaint to August 18, 2010. Respectfully submitted, DATED: July 14, 2010 /s/Melissa Richards Smith Melissa Richards Smith Texas State Bar No. 24001351 GILLAM & SMITH, L.L.P. 303 South Washington Avenue Marshall, Texas 75670 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] ATTORNEY FOR PLAINTIFF

RV Media, LLC d/b/a PR 18 Network (pro se) c/o V. Dave Incorp Services, Inc. 815 Brazos Street, Suite 500 Austin, Texas 78701 Telephone: [phone] E-mail: [e-mail] DEFENDANT

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 document 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 U.S. mail or facsimile transmission, on this the 14th day of July, 2010. /s/Melissa Richards Smith Melissa Richards Smith