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

Filing 28

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

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. SECOND 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.

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. 5. On August 16, 2010, RV Media, LLC d/b/a PR 18 Network (pro se) sought a

second extension from Plaintiff to respond to Plaintiff's Complaint, and Plaintiff agreed to an extension, until September 28, 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 September 28, 2010. Respectfully submitted, DATED: August 16, 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 16th day of August, 2010. /s/Melissa Richards Smith Melissa Richards Smith